Jane B. Oliver and Robert P. Oliver - Page 47

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          III.  Issue 8.  Interest Income                                             
               Section 61(a) provides that gross income means all income              
          from whatever source derived.  Section 61(a)(4) provides that               
          gross income includes interest.                                             
               Respondent contends that petitioners failed to report                  
          interest income of $2,824 on their Federal income tax return.               
          Information returns provided to respondent show that petitioners            
          received $17,952 in interest income in 1990.  Petitioners                   
          reported only $15,128 as interest income on their 1990 return.              
               Petitioners contend that $633 of the unreported interest               
          income paid by Allstate Life Insurance Co. (Allstate) was not               
          taxable.  They submitted a letter from Allstate, which they claim           
          explained that the interest was not taxable.  The letter does not           
          support their contention.                                                   
               Petitioners have offered no evidence as to the remaining               
          amount of unreported interest income determined by respondent.              
          However, respondent presented testimony and documentary evidence            
          showing that petitioners received $2,824 in interest income which           
          was not reported on their 1990 return.  Therefore, respondent is            
          sustained on this issue.                                                    
          IV.  Issue 9.  Claimed Deductions for Self-Employment Taxes                 
               Section 275(a)(1) provides that no deduction shall be                  
          allowed for Federal income taxes.  However, section 275 does not            
          apply to disallow a deduction for taxes to the extent such a                
          deduction is allowable under section 164(f), which provides that            




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