Domer L. Ishler - Page 2




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                                   Domer L. Ishler                                    
                         Additions to tax                                             
          Year  Deficiency  Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661           
          1987   $112,227       $84,170                 1          $28,057            
          1988    396,659       297,494                 --          99,165            
               1 50 percent of the interest due on $112,227.                          
                            20th Century Marketing, Inc.                              
                              Additions to tax                                        
          Year ended  Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661      
          Dec. 31,    $118,314       $88,736                1          $29,579        
          1987                                                                        
               1 50 percent of the interest due on $118,314.                          
               Domer L. Ishler (petitioner) was president and owned all of            
          the stock of petitioner corporation, 20th Century Marketing, Inc.           
          (TCM).  TCM earned commissions on sales of electronic components            
          to Chrysler Corp.  Petitioner arranged for a Hong Kong                      
          corporation, Camaro Trading Co., Ltd. (Camaro), to receive                  
          commissions which otherwise would have been paid to TCM.  The               
          issues in dispute primarily relate to whether Camaro was paid for           
          services performed by Camaro, as petitioner contends, or as a               
          device to avoid taxation of most of that commission income, as              
          respondent contends.                                                        













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