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purposes, certain business records of MBL which stated that,
during 1990, MBL paid to petitioner wage income in the amount of
$468,218.34.
Petitioners contend that, during 1990, petitioner received
no wage income from MBL but did receive $308,936 from Stuart
Financial Planning Corp. (Stuart). Petitioners argue that, at
the audit, they established that MBL paid Stuart, which paid
$308,936 to petitioner. Additionally, petitioners argue that
they reported income that was deposited in petitioners' account
at NationsBank for their 1990 taxable year. Alternatively,
petitioners argue that petitioner merely collected income in the
role of agent and, therefore, is not required to include that
amount in gross income.
Respondent has shown that, during taxable years 1990 and
1991, petitioner received from MBL wage income in the amounts of
$468,218.34 and $98,726.62, respectively. Mr. Gelcius testified
that MBL made payments to petitioner in the amount of $468,218.34
for 1990 and in the amount of $98,726.62 for 1991. Mr. Gelcius'
testimony as to the payments made to petitioner during 1991 is
corroborated by the parties' stipulation that petitioner received
from MBL wages in the amount of $98,726. Additionally, at trial,
Mr. Gelcius' testimony was neither discredited nor contradicted
by petitioner.
Petitioners argue that MBL paid Stuart, which then paid
petitioner. At trial, however, petitioner did not present
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