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We hold for respondent on this issue, except that we hold
for petitioner as to $16 for 1985.
C. Royalty Income--198311 Through 1986
Petitioner contends that he reported all income that was
known to him, and that he had no income other than what he
reported on his tax returns for the years in issue.
Respondent contends that petitioner received and failed to
report royalty income in the amounts of $30,870 for 1983, $29,596
for 1984, $2,313 for 1985, and $13,230 for 1986.
We agree with respondent as to 1983, 1984, and 1986; we
agree with petitioner as to 1985.
(1) 1984 and 1986
Forms 1099 reporting royalty income distributed to
petitioner were issued to petitioner for 1984 by seven payors and
for 1986 by five payors. Petitioner has not challenged the
accuracy of these forms.
The Form 1099 information matches respondent's royalty
determinations in the notice of deficiency for 1984 and 1986,
except for $6,408 withholding as to 1984. See note 1 to table 6,
supra. Respondent determined that Phillips Petroleum Co. paid
$32,213 royalty income to petitioner in 1984. This matches the
11On brief, respondent conceded the $10,329 royalty income
adjustment for 1982 ($24,647 royalty income determined, less
$14,318 royalty income reported) because "Any underreported
royalty income for 1982 would have been included in the
adjustment * * * based on the source and application of funds
calculation." See our discussion of this matter supra in the
text following note 9 reference.
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