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findings with respect to the IMA statements on the grounds that
petitioner’s testimony was self-serving and uncorroborated. That
is true, but it does not necessarily mean that petitioner’s
testimony was false or unpersuasive. Petitioner was a credible
witness, and his unrebutted testimony is sufficient to carry his
burden of proving advance commissions for 1992 and 1993 of
$119,488 and $202,404, respectively, and we so find.
3. Liability
Gross income includes compensation for services, including
commissions on insurance premiums and compensation for services
to be performed in the future. Beaver v. Commissioner, 55 T.C.
85, 91 (1970) (future services). Sec. 61(a)(1); sec. 1.61-
2(a)(1), Income Tax Regs. (specific reference to commissions on
insurance premiums). An amount received by a taxpayer as a loan,
however, does not constitute an item of gross income because of
the obligation of the taxpayer to repay the amount received. See
James v. United States, 366 U.S. 213, 219 (1961).
Pursuant to the agreement, petitioner earned a commission on
insurance sold by him or by others working under his supervision.
Petitioner’s commissions were a percentage of the premiums paid
on the insurance sold by him or by those others. Petitioner
earned a commission only as the insurance company writing the
insurance earned a premium and IMA received payment from that
company. IMA had discretion to pay advance commissions on
insurance written by petitioner. At the time those advance
commissions were paid, the insurance had already been written
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