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His testimony was vague, unsupported by any billing records or
any other tangible work product that would indicate the business
or tax-related nature of the work, and does not convince us that
any of the expense was related to petitioner's trade or business
or tax-related matters. Cf. United States v. Gilmore, 372 U.S.
39 (1963) (to be deductible as a business or profit seeking
expense, it is insufficient that an expenditure have a business
or income-related consequence if the origin of the expense is not
in the business or profit seeking activity). We accord
Mr. Bentley's testimony no weight, and, thus, petitioner has
failed to carry his burden of proof on this matter. Respondent’s
determination of a deficiency is sustained to the extent
respondent denied petitioner’s deduction for the Bentley payment.
IV. Payment From Radiology Affiliates
Radiology Affiliates of NY (Radiology Affiliates) employed
petitioner during 1993. Petitioner received $30,000 from
Radiology Affiliates during 1993 (the $30,000 payment), which he
did not report as gross income. Respondent determined that the
$30,000 payment was compensation for services to be performed in
the future and increased petitioner’s gross income by $30,000 on
account thereof. Petitioner argues that the $30,000 payment was
not an item of gross income because it was a loan.
Generally, compensation for services is an item of gross
income, including compensation received for future services.
Sec. 61(a)(3); e.g., Huebner v. Commissioner, T.C. Memo. 1966-73
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