John Bresnahan - Page 2

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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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