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HARKINS v. COMMISSIONER

Docket No. 15623-99.

81 T.C.M. 1547 (2001)

T.C. Memo. 2001-100

Daniel E. and Karen A. Harkins v. Commissioner.

United States Tax Court.

Filed April 26, 2001.

Attorney(s) appearing for the Case

Tim A. Tarter, for the petitioners.

John W. Duncan and Ann M. Welhaf, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge.

Respondent determined a deficiency of $111,311 in petitioners' 1996 Federal income tax. After various concessions,1 the issues presented to us are (1) whether petitioners must report as income in 1996 amounts paid during 1996 by Pepsi-Cola Co. (Pepsi) to Daniel E. Harkins' (Mr. Harkins') solely owned S corporation and (2) whether petitioners must report as income in 1996...

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