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BarSon's funds to pay their personal expenses and did not intend
to repay these funds, we sustain respondent's determination on
this issue.21
Issue 3. Interest Income
Respondent determined that petitioners received taxable
interest of $7,791, $37,612, and $8,429 in 1980, 1981, and 1982,
respectively, from the funds deposited at the Bank. Petitioners
allege that they did not receive any interest from the Bank
because they never had an interest-bearing account there.
We agree with respondent's determination. Gross income
includes interest. Sec. 61(a)(4). Interest of $15,582, $75,224,
and $16,858 was earned in 1980, 1981, and 1982, respectively, on
the commissions deposited at the Bank. Petitioner and Dr. Young
had unfettered access to this interest, as well as to the
underlying funds. Petitioner and Dr. Young controlled the
activities of the accounts. Given the fact that petitioner was
one of two beneficial owners of the bank accounts that generated
the disputed interest, we sustain respondent's determination that
half of the interest earned on the accounts was realized by him.
21 Petitioners have also failed to persuade us that any of
the distributions were business expenses of BarSon.
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