16 interest income as either patronage or nonpatronage-sourced income has been at issue since the pleadings were filed. A taxpayer bears the burden of proving allegations it makes in the petition when it submits a case fully stipulated. Rules 122, 217(c)(1)(A); Kitch v. Commissioner, 104 T.C. 1, 5 (1995). The stipulation does not include facts that support a finding that petitioner's interest income was patronage sourced. The record includes nothing to suggest that petitioner’s interest income was earned from required reserves or that petitioner maintained its savings and money market accounts and certificates of deposit for business, rather than investment, purposes. Petitioner failed to carry its burden of proving that its interest income was patronage sourced under section 1388. We hold that petitioner's interest income is taxable to petitioner as determined by respondent. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011