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taxpayer realizes income if he controls the disposition of that
which he could receive himself but diverts to another as a means
of procuring the satisfaction of his goals. The receipt of
income by the other party under such circumstances is merely the
fruition of the taxpayer's economic gain. See Commissioner v.
Sunnen, supra at 605-606; Helvering v. Horst, 311 U.S. 112, 116-
117 (1940).
In this case, petitioners attempted to assert that they had
taken "vows of poverty" assigning "Any and all funds" to a
religious institution(s).5 Petitioners offered no evidence to
substantiate their claim. When secular services are rendered by
individuals, income received by them in an individual capacity
and not on behalf of a separate and distinct principal is taxable
to the individuals. See Pollard v. Commissioner, 786 F.2d 1063
(11th Cir. 1986), affg. T.C. Memo. 1984-536; McGahen v.
Commissioner, 76 T.C. 468 (1981), affd. without published opinion
720 F.2d 664 (3d Cir. 1983); Kelley v. Commissioner, 62 T.C. 131
(1974). Accordingly, we find the income earned by petitioners
for landscaping services is taxable to them individually.
5We see no need to address whether Mountlake is a church or
other religious institution. Petitioners did not assert at trial
or on brief that the income assigned to Mountlake qualified for
the charitable contribution deduction under sec. 170. In
addition, since Mountlake is not a sec. 501(c)(3) organization,
there is no presumption that petitioners' contributions to the
organization are deductible from their taxable income. See sec.
170(c) (defining deductible charitable contribution).
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