Ralph E. and Mildred E. Galyen - Page 7

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          the years at issue, the Galyen Agency had less than $1 million in           
          annual sales and fewer than 30 employees.  The Galyen Agency                
          subscribed to the program for the taxable years 2000, 2001, and             
          2002.  On the subscription for each year, the Galyen Agency chose           
          promotional service program C.  The subscription contracts do not           
          include the names of the referrals made by the Galyen Agency.               
          The Galyen Agency paid AdaCom $2,500 and was credited with $7,750           
          in promotional services.                                                    
               The gross income of the Galyen Agency for the taxable years            
          2000, 2001, and 2002 was $272,052, $210,847, and $21,803,                   
          respectively.  These amounts included $7,750 each year as                   
          bartering income for promotional services from AdaCom.                      
               On the basis of the subscriptions to the program, the Galyen           
          Agency claimed a $5,250 business expense deduction and a $5,000             
          section 44 credit on Form 1120S, U.S. Income Tax Return for an S            
          Corporation, for each of the years 2000, 2001, and 2002.                    
               On their Form 1040, U.S. Individual Income Tax Return, for             
          taxable years 2000, 2001, and 2002, petitioners reported Schedule           
          K-1, Shareholder’s Share of Income, Credits, Deductions, etc.,              
          distributive shares of $83,324, $39,921, and $8,935 of nonpassive           
          income from the Galyen Agency, respectively.                                
               Respondent determined deficiencies in petitioners’ Federal             
          income tax for 2000, 2001, and 2002 in the amounts of $3,323,               
          $3,556, and $3,126, respectively, after decreasing petitioners’             






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