47- - 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 thatPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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