T.C. Memo. 2000-228 UNITED STATES TAX COURT JAMES R. PALMER AND LINDA D. PALMER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19171-98. Filed July 28, 2000. Ruth A. Rowlette, for petitioners. Christian A. Speck, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: Respondent determined a deficiency of $44,375 in petitioners’ Federal income tax for 1995. The issues remaining for decision are: (1) Did petitioner James R. Palmer (Mr. Palmer) construc- tively receive during 1995 $95,935 of compensation that he did not actually receive until after that year? We hold that he did.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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