John R. Hernandez - Page 8

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          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               





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