Tae M. & Young J. Kim - Page 6

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          from the sale of certain stock of a company described as “TRAVEL-           
          ERS PROP”, and $8 of interest income from Washington Savings Bank           
          in excess of the $521.61 of interest income from that bank shown            
          in the 2002 Schedule B included as part of petitioners’ 2002                
          return.  Respondent based the foregoing determinations on infor-            
          mation returns that the respective payers provided to respondent.           
               On December 12, 2005, after petitioners filed the petition             
          commencing this case, respondent received from petitioners Form             
          1040X, Amended U.S. Individual Income Tax Return, with respect to           
          their taxable year 2002 (petitioners’ 2002 amended return).  In             
          petitioners’ 2002 amended return, petitioners reduced by                    
          $4,234.94 the adjusted gross income reported in petitioners’ 2002           
          return and claimed a refund of $1,255.  In support thereof,                 
          petitioners gave the following explanation in petitioners’ 2002             
          amended return:  “Excluding $4,234.94 ESPP gain from W-2.  In-              
          cluding $4,234.94 ESPP gain in Capital Gains on Schedule D.”                
          Petitioners included as part of petitioners’ 2002 amended return            
          a copy of the 2002 Schedule D that they included as part of                 
          petitioners’ 2002 return, on which they made certain changes.               
          (We shall refer to the copy of the 2002 Schedule D on which                 
          petitioners made certain changes as petitioners’ amended 2002               
          Schedule D.)  Petitioners made the following changes in petition-           
          ers’ amended 2002 Schedule D.  Petitioners claimed short-term               
          capital gains totaling $4,234.94 from the sales of certain Fannie           






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