- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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