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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.
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