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Respondent determined a deficiency in petitioner's 1991
Federal income tax in the amount of $4,012.
The sole issue for decision is whether petitioner reported
the correct amount of income from a grantor trust.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. Petitioner resided in
Shrewsbury, Massachusetts, at the time he filed his petition.
Background
Petitioner created a grantor trust which derived income from
leasing safe deposit boxes to the Midwest Federal Savings Bank.
The trust issued to petitioner a "1041 Supplement" indicating net
income attributable to petitioner in 1991 of $87,519. On his
1991 Federal income tax return, however, petitioner only reported
$74,955 of net income from the trust.
Respondent determined that petitioner's share of income from
the trust is $87,519 and, accordingly, that petitioner had
unreported income in the amount of $12,564 ($87,519 trust income
less $74,955 trust income reported).
Discussion
Petitioner concedes that he had unreported income in the
amount of $5,831 and, accordingly, that his share of trust income
should be $80,786. However, petitioner contends that the "1041
Supplement" he received from the trust is incorrect. Petitioner
contends that his share of trust income should include an
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