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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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