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signatory company to the IATSE agreement.
Petitioner’s music editing services were provided to the
studios in accordance with a deal memorandum or a loan-out
agreement which memorialized some of the terms of those
contracts. Daryl Kell’s personal services as a music editor were
specifically designated as required in the deal memorandum and
loan-out agreement. The loan-out agreement and deal memorandum
provide that Daryl Kell "render music editorial services,
whenever and wherever the producer may require." The payments
made to petitioner were supplemented by payments to IATSE for
benefits accruing to Daryl Kell under the IATSE agreement.
Petitioner's general ledgers were prepared by Jessica
Shields-Hamper. Jessica Shields-Hamper is petitioner's and Daryl
Kell's agent. Petitioner’s 1996 tax return was prepared by
Robert Fogelman, C.P.A. Petitioner’s 1997 return was prepared by
Steven McNulty of Feddersen & Co. C.P.A.(s).
For the 1996 tax year, petitioner reported total income of
$133,977, of which the following amounts were for music editing
services:
Film Editing Income
Fair Game $70,227
Moll Flanders 28,955
Other editing income 10,415
Total 109,597
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Last modified: May 25, 2011