Joseph B. Zinn - Page 4




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          Treasury Bills                                                              

                                      Purchase/          Refund/                      
                      Par    Purchase   Issue   Maturity Interest                     
          CUSIP No. Amount    Price     Date      Date   Payment                      
          9127944T8 $20,000 $18,855.4004/03/97  04/02/98 $1,144.60                    
          9127944U5 $20,000  18,843.2005/01/97  04/30/98  1,156.80                    
          9127944WJ $25,000  23,642.7506/26/97  06/25/98  1,385.25                    
          9127945A8 $20,000  18,948.4010/16/97  10/15/98  1,051.60                    

          Inflation-Indexed Debt Instrument                                           
                                                                   Original           
                                                                    Issue             
                                                         Original  Discount           
                      Par    Purchase   Issue   Maturity   Issue   Reporting          
          CUSIP No. Amount    Price     Date      Date   Discount   Period            
          9128272M3 $15,000 $14,922.3002/06/97  01/15/07    227.25 12/31/97-          
                                                                   12/31/98           
               Petitioner timely filed his 1998 tax return without                    
          reporting the interest income or original issue discount income             
          listed above.                                                               
               Respondent issued a notice of deficiency determining that              
          petitioner received interest income totaling $4,927 upon the                
          maturation of four U.S. Treasury bills in 1998 and the receipt of           
          original issue discount income representing an increase in value            
          of the inflation-indexed debt instrument in 1998.  The                      
          Commissioner relied on Forms 1099 furnished by the Bureau to                
          determine the omitted income in question.                                   
               Petitioner contends that the U.S. Treasury instruments in              
          issue did not mature in 1998, but rather were purchased in 1998,            
          and, therefore, are not includable in income in 1998.                       





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