James O. Jondahl - Page 40

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         by Taxman.  Petitioner therefore must include the $2,147 as                  
         compensation income in 1990.                                                 
                   2.   Unreported Income in 1991                                     
              In 1991, Taxman accepted a stereo worth $509 from a client              
         in exchange for a corresponding reduction in the client’s bill.              
         Petitioner then gave the stereo to his girlfriend, Ms. Lane.                 
         Respondent argues that petitioner’s income should be adjusted by             
         $509 to reflect the value of the stereo.  Petitioner argues that             
         he gave Ms. Lane the stereo and in exchange she worked in a                  
         Taxman Express office for 1 month.  We believe the stereo was                
         compensation to Ms. Lane from Taxman.  Ms. Lane credibly                     
         testified that she worked at the Taxman Express office because               
         she wanted to pay petitioner back for the stereo after she                   
         received it.  We believe the arrangement between petitioner and              
         Ms. Lane resulted in a benefit to Taxman that is equal to or                 
         greater than the value of the stereo.  As a result, we do not                
         believe that the value of the stereo is income to petitioner.                
              Taxman paid petitioner $2,052 in 1991.  Petitioner argues               
         that as a result of the 1987 audit, the $2,052 was removed from              
         his personal Schedule C because it was an expense of Taxman.  He             
         claims that in order for Taxman to take the expense as a                     
         deduction, the revenue agent advised him that Taxman should                  
         reimburse petitioner for the amount of the expense in 1991.                  
         Therefore, petitioner argues that the $2,052 was not income to               






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