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GARCIA v. COMMISSIONER

Docket No. 13649-10.

140 T.C. 141 (2013)

SERGIO GARCIA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 14, 2013.

Attorney(s) appearing for the Case

Thomas V. Linguanti, Jenny A. Austin, Jason D. Dimopoulos, Robert F. Hudson, Jr., and Robert H. Moore, for petitioner.

W. Robert Abramitis, Tracey B. Leibowitz, and Karen J. Lapekas, for respondent.

GOEKE, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $930,248 and $789,518 for tax years 2003 and 2004, respectively, as a result of income he purportedly received during those years through an endorsement agreement with TaylorMade Golf Co. (TaylorMade). After concessions, the issues for decision are:

(1) the extent to which payments made by TaylorMade under the endorsement agreement are compensation for the performance...

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