Charles A. Dennis and Alison M. Dennis - Page 4

                                        - 4 -                                         
                                  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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