Annisa M. Owens - Page 7

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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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