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of Receipts of Annuities, Pension, Retired Pay or IRA Payments,
from the State of Illinois issued to Eva F. Berglund reflecting
in block 10 of said form taxable pension payments of $3,482.29,
$3,567.13, and $3,651.97, respectively. On their Federal income
tax returns for 1986, 1987, and 1988, petitioner and his spouse
did not report as taxable any amount of pension income received
by petitioner's spouse from her former employment as a school
teacher.
Petitioner and his spouse reported the receipt of $8,192 in
Social Security benefits on line 21a of their joint Federal
income tax return for 1986 but did not report as taxable any
portion of those benefits on line 21b of their 1986 return.
On their joint Federal income tax returns for 1987 and 1988,
petitioner and his spouse did not report the receipt of income in
the form of ASCS payments in the amounts of $11,198.96 and
$11,298, respectively. Petitioner admits that in 1987 ASCS
payments in the amount of $11,198.96 were applied to the FHA
mortgage. Additionally, in a power-of-direction dated April 28,
1989, petitioner and his spouse stated that their agent, FNB, was
holding "the 1989 ASCS contract and proceeds thereof".
Petitioner filed his brief with various documents attached
that had not been introduced at trial. Petitioner does not
contest that his and his spouse's farmland was in fact sold;
rather, petitioner contends that he and his wife were tricked
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