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reported a $2,558 capital loss with respect to one of the Strong
Total Return Fund Accounts he held in joint tenancy with his
daughter. In addition, petitioner listed said accounts as his
assets on loan applications prepared and filed during the period
at issue. The accounts produced the following dividends for the
years at issue:
Account 1988 Dividends 1989 Dividends 1990 Dividends
Franklin Money
Fund Acct. No.
11100662247 $2,051.29 $3,460.72 $2,849.23
Strong Fund
Acct. No.
021-2021885157 128.38 135.89 ---
Strong Fund
Acct. No.
023-2300221719 901.56 1,157.64 1,010.55
Strong Fund
Acct. No.
028-2800101143 42.34 409.37 561.85
Total Dividends 3,123.57 5,163.62 4,421.63
The dividend amounts shown above were reported on Jennifer
Beretta's income tax returns for the years at issue. Respondent
determined that petitioner maintained control of the investment
accounts, and therefore included the dividend amounts in
petitioner's income for taxable years 1988, 1989, and 1990
respectively.
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Last modified: May 25, 2011