James W. Harris and Dorthy R. Harris - Page 5

                                       - 5 -                                          
          escrowee, and NBA was generally directed to remit identical                 
          amounts to Seafirst to apply to the debt owed it by petitioners.            
          Following petitioners' sale of the home, Seafirst assigned                  
          petitioners' debt to Union Planters National Bank (Union                    
          Planters).  NBA collected $13,495 from the Turners in 1992, and             
          it distributed $13,369 to Union Planters on behalf of                       
          petitioners.  NBA ascertained that $11,880 of the $13,495 amount            
          was interest, and it issued petitioners (and respondent) a Form             
          1099-INT reflecting this amount.3  Respondent determined that               
          petitioners failed to include in income the $11,880 of interest             
          shown on the Form 1099-INT, and, accordingly, that their interest           
          income for 1992 was understated by $11,801; i.e., the $11,984               
          total amount reported on the three Forms 1099-INT issued to                 
          petitioners, less the $183 amount reported on petitioners' tax              
          return as interest from sources other than the Alaskan permanent            
          fund ($2,015 - $1,832).                                                     
               As to the claimed loss of $73,129, Harris Enterprises is               
          Mr. Harris' sole proprietorship through which he rented (as                 
          lessor) approximately 20 mini storage units in a                            
          6,000-square-foot building.  On one or two other occasions,                 
          Harris Enterprises also rented two other buildings for use as               
          space in which to hold auctions or flea markets.  According to              

          3 Union Planters ascertained that petitioners had paid it                   
          $9,833 of interest in 1992 on their debt to it.  Union Planters             
          issued a 1992 Form 1098, Mortgage Interest Statement, to                    
          petitioners reflecting this amount.                                         




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011