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Because MCP served as his agent for making the sales and
receiving the sales income, the only limitations placed on
petitioner’s receipt of that income were self-imposed and
therefore ineffective to achieve a deferral for tax purposes.
On this record, we conclude that petitioner constructively
received the yearend value-added payments during the respective
taxable years in issue.
Lastly, because we have held petitioners taxable in 1994 and
1995, we find that petitioners are entitled to offsetting
adjustments in each of the respective years to take into account
the yearend value-added payments previously reported as income
for those years. Sec. 481.
Contentions we have not addressed are irrelevant, moot, or
meritless.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011