- 43 -
We agree almost entirely with respondent.
Forms 1099 reporting interest paid to petitioner were issued
to petitioner for 1984 through 1986 by five payors. Petitioner
has not challenged the accuracy of these forms; thus we do not
reach the issue involved in Portillo v. Commissioner, 932 F.2d
1128 (5th Cir. 1991), affg. in part and revg. in part T.C. Memo.
1990-68.
The Form 1099 information matches respondent's interest
determinations in the notice of deficiency, except for $16 as to
1985. See supra table 5. Respondent determined that First
Oklahoma Savings Bank paid $89 to petitioner in 1985. However,
the Form 1099 information that the parties stipulated shows only
$73. Although petitioner has made general denials about
receiving income in excess of what he reported, they are not
directed to any specific interest item. Thus, apart from the one
$16 discrepancy, the little evidence that is in the record
supports respondent's determination. In any event, petitioner has
otherwise failed to carry his burden of proving respondent's
determination to be in error. Rule 142(a);10 Welch v. Helvering,
290 U.S..111, 115 (1933).
From the foregoing we conclude, and we have found (supra
table 5), that petitioner received and failed to report interest
income in the amounts of $2,115 for 1984, $2,256 for 1985, and
$2,287 for 1986.
10Unless indicated otherwise, all Rule references are to the Tax
Court Rules of Practice and Procedure.
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