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Harrington v. Commissioner, T.C. Memo. 1958-194 (finding on the
basis of social activities and vacations a personal relationship
existed between the taxpayers and the husband's employers).
Petitioner is unable to establish that she had a
relationship with Mr. Kroner other than that of employer-
employee. Indeed, she testified that she did not have a
relationship with Mr. Kroner outside of the work environment.
Petitioner offered no evidence that would indicate that the
$7,500 was paid for any purpose other than to reward her for
excellent job performance. It appears to the Court that Mr.
Kroner was paying petitioner for the services she provided to him
as his executive assistant. The regulations expressly provide
that Christmas bonuses are included in the definition of
compensation. Sec. 1.61-2(a), Income Tax Regs.
The parties agree that petitioner received a check for
$7,500 from Mr. Kroner. Furthermore, the evidence indicates that
petitioner endorsed and deposited the check she received from Mr.
Kroner into her personal account. The Court holds that
petitioner is required to include the $7,500 in income.
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