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FINDINGS OF FACT
Bank Fees
Petitioners failed to include $45 of interest income, earned
from their bank account, on their 1991 income tax return. There
was no evidence presented as to whether the bank account was
personal or business. At the time of filing of their return,
petitioners reasoned that because they incurred $48 of bank fees
in obtaining such interest, they could net the two and exclude
the income and not claim the deduction. Petitioners conceded
that the interest was properly includable in income for the 1991
tax year, but claim that they are entitled to a $48 deduction as
an ordinary and necessary trade or business expense for the 1991
taxable year.
Unreported Income
During 1991, petitioner purchased from Doug Priester
insurance policies on himself, his wife, and his children. Doug
Priester issued a Form 1099 to the Internal Revenue Service and
(allegedly) to petitioners, indicating that petitioners had
received $3,577 as gross income in the form of a discount on
insurance sold to them. Respondent determined in the notice of
deficiency that petitioners failed to report the $3,577 in gross
income for the 1991 tax year. Petitioner argues that he did not
receive a copy of Form 1099, that he was not in the position to
have performed services for Doug Priester for which payments may
have been made, and that he received no money from Doug Priester.
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