Earnest and Laura Tillman - Page 12

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          2.  Additional Schedule A Deductions                                        
               For reasons similar to those stated above, we agree with               
          respondent that petitioners may not deduct more interest or taxes           
          on their Schedules A than she has allowed.  We hold for                     
          respondent on this issue.                                                   
          3.  Taxability of Unemployment Compensation                                 
               Gross income includes unemployment compensation.  Sec.                 
          85(a).  Given the facts that Mrs. Tillman received $1,152 of                
          unemployment income in 1989, and that petitioners did not report            
          this amount on their 1989 tax return, we must hold for respondent           
          on this issue.                                                              
          4.  Unreported Sales Income                                                 
               Gross income includes income from whatever source derived.             
          Sec. 61(a).  Petitioners agree that Trucking received $43,621 and           
          $43,475 in gross receipts from Crawford during 1990 and 1991,               
          respectively, and that petitioners’ tax returns reported only               
          $21,424 of these receipts for 1990 and none of them for 1991.  We           
          hold that petitioners failed to report $22,197 in sales income              
          for 1990, and $43,475 in sales income for 1991.                             
          5.  Receipt of Insurance Proceeds                                           
               A taxpayer realizes gain on a conversion (e.g., a loss) to             
          the extent that the insurance proceeds connected thereto exceed             
          the adjusted basis of the underlying property.  Sec. 1001(a).               

          6(...continued)                                                             
          taking title, or in which he has no equity.                                 




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