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in petitioner’s income: (1) Under the assignment of income
doctrine; (2) because Universal was a sham; or (3) if Universal
was not a sham, because Universal’s income is taxable to
petitioner under the grantor trust rules. Respondent has
conceded that petitioner is entitled to a small amount of trade
or business deductions relating to this income.
Petitioner maintains that the $103,420 is Universal’s
income, or in the alternative, contends that he is entitled to
business deductions that offset the income.
Petitioner has filed a “Motion for Summary Disposition
and/or Judgment” contesting the validity and effect of the
statutory notice. Petitioner has also filed a Motion in Limine
contesting respondent’s ability to make certain arguments or
introduce certain evidence. Because our disposition of these
motions could affect our consideration of the substantive issues,
we turn our attention to them now.
I. Petitioner’s Motion for Summary Judgment
According to petitioner’s summary judgment motion,
respondent has failed to establish a sufficient link between
6(...continued)
services performed by petitioner.
The record also establishes that $1,341 of the $104,786
deposited in Universal’s account was paid for services performed
by Ms. Ghavami. The record contains no information about the
proper treatment of the remaining $25 deposited in the Universal
account ($104,786 minus $103,420 and $1,341 equals $25).
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