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PALMER v. COMMISSIONER

Docket No. 19171-98.

80 T.C.M. 101 (2000)

T.C. Memo. 2000-228

James R. Palmer and Linda D. Palmer v. Commissioner.

United States Tax Court.

Filed July 28, 2000.

Attorney(s) appearing for the Case

Ruth A. Rowlette, for the petitioners. Christian A. Speck, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined a deficiency of $44,375 in petitioners' Federal income tax for 1995.

The issues remaining for decision are:

(1) Did petitioner James R. Palmer (Mr. Palmer) constructively receive during 1995 $95,935 of compensation that he did not actually receive until after that year? We hold that he did.

(2) Was the $5,100 that Mr. Palmer received during 1995 with respect...

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