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.
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