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Mr. Comey’s only argument is that these amounts are not his
income, because he received them as Landtrak’s nominee.
Amounts Received by Mr. Comey in 1992
On a Schedule B, Interest and Dividend Income, attached to
his Form 1040 for 1992, Mr. Comey reported receiving $75 of
interest and $16,024 of dividends. The dividends were paid by 18
of the 21 corporations that had paid dividends to Mr. Comey in
1991.
On a Schedule D, Capital Gains and Losses, attached to his
Form 1040 for 1992, Mr. Comey reported that he had received
proceeds of $5,070 on the sale of the AT&T debenture.
Although Mr. Comey reported the interest, dividends, and
sale proceeds on the Schedules to his 1992 return, he did not
include them in his income on the Form 1040. As he had done for
1991, Mr. Comey described these amounts as “nominee
distribution[s]”. Mr. Comey reported total income of only $5,103
on his Form 1040 for 1992.
In the notice to Mr. Comey for 1992, respondent determined
that the $75 of interest and the $16,024 of dividends were Mr.
Comey’s income. Respondent also determined that the $5,070 sale
proceeds were taxable to Mr. Comey as capital gain.
Mr. Comey admits that he received the $16,024 of dividends.
He also has neither contested that he received the $75 of
interest and the $5,070 proceeds, nor asserted that he is
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