- 8 -
3 Only half of this amount ($3,569.85) was included in respondent’s
adjustment to income in statutory notice of deficiency because J. Campbell
reported other half as income.
4 Sec. 6012(d) requires that taxpayers report all interest received or
accrued that is exempt from the tax imposed by ch. 1.
“T. Collins” was petitioner’s daughter, Mrs. Collins. “D.
Collins” was petitioner’s granddaughter, Mrs. Collins’ daughter.
Mrs. Collins was also listed as an alternate payee under the name
“T.H. Coleman”. Mrs. Collins reported $445.09 of interest on her
income tax return for tax year 1990 and $330.53 on her income tax
return for tax year 1991 as either income or tax-exempt interest.
“D.H. Craig” was Mrs. Craig, petitioner’s other daughter.
“Mark Craig” was petitioner’s grandson. Mrs. Craig was his
mother. Mark Craig did not report any interest from amounts
received in redemption of tax certificates on income tax returns
during those years. In a letter response to an inquiry by
respondent’s counsel, Mrs. Craig stated that petitioner was
acting as her agent in holding the amounts of $4,713.06 for 1991
and $974.56 for 1992 of her income. However, Mrs. Craig did not
disclose those amounts on her income tax returns for either year
as either income or tax-exempt interest, nor does the record show
that petitioner held such amounts in trust or that he paid taxes
on those amounts as trustee.
Mrs. Craig had two other children who were listed as
“Eric B. Craig” and “Nicole E. Craig” as alternate payees of
interest received in redemption of tax certificates. Neither
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011