Robert and Lisa Morganstein - Page 3




                                        - 2 -                                         
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $21,725 and $5,002 for the taxable years 1996 and           
          1997.                                                                       
               The issue for decision is whether certain payments received            
          by BMP Entertainment, Inc., an S corporation wholly owned by                
          petitioner husband, are includable in income in the year in which           
          they were received or in the year in which the corresponding                
          services were rendered.1                                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Huntingdon Valley, Pennsylvania, on the date the petition was               
          filed in this case.                                                         
               During the years in issue, petitioner husband (petitioner)             
          was the sole shareholder of an S corporation named BMP                      
          Entertainment, Inc. (BMP).  BMP’s business consists of providing            
          entertainment for parties in the form of disc jockey and related            
          services, primarily for bar mitzvahs.  Petitioner often would               
          enter into contracts on behalf of BMP for services to be rendered           
          up to several years later.  The contracts were based upon a                 
          standard form contract which provided nearly identical terms for            
          each customer.  In order to reserve a future date, customers were           


          1Respondent’s adjustment to petitioners’ miscellaneous                      
          itemized deductions is computational and will be resolved by the            
          Court’s holding on the issue in this case.                                  




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