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Addition to Tax
Sec.
Year Deficiency 6651(a)(1)
1987 $17,835 $4,459
1988 21,529 5,382
1989 36,911 9,228
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue for decision is whether certain income that
petitioner received in 1988 and 1989 qualifies under section
871(h) as nontaxable interest on qualified "portfolio debt
investments".
FINDINGS OF FACT
Many of the facts have been stipulated and are so found. At
the time the petition was filed and during the years in issue,
petitioner resided in Ocana, Colombia.
From 1937 to 1941, petitioner attended college in the United
States and during those years petitioner obtained a U.S. Social
Security number. In 1941, petitioner returned to Colombia.
Since 1941, petitioner has resided in Colombia.
In November of 1988, with assistance from a sister who
resided in the United States, petitioner invested $1,015,489 in a
mutual fund with respect to which petitioner received U.S. source
interest and dividend income.
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Last modified: May 25, 2011