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this denial, but the Court of Appeals dismissed his appeal for
failure to pay docket fees.
Petitioner’s Income From the Kidder Peabody Account
During 1991, petitioner’s account earned $698.85 in interest
income, $15,882.21 in dividends, and an additional $458.41 in
proceeds from miscellaneous sales of securities. At the time of
the liquidation, in December of 1991, the balance in petitioner’s
account reflected a minus $141,400.64. Kidder Peabody liquidated
petitioner’s account in November and December of 1991. The
subsequent liquidation produced proceeds of $387,686.49. Kidder
Peabody used some of the cash from the proceeds to pay off
petitioner’s negative account liability. It sent the remaining
funds, in five checks totaling $246,976.40, to petitioner.2
On his Federal income tax return for 1991, petitioner failed
to report the dividend income from his account with Kidder
Peabody. On Schedule B of the return, where interest income from
Kidder Peabody should have been reported, petitioner wrote in the
word “LITIGATION”. On Schedule D of his return, in the space for
reporting long-term capital gains, petitioner wrote “NONE”. On
2 This figure includes the net amount of interest income
($192.91) plus dividends received during December 1991 ($674.37)
less accrued interest expense for that month ($176.73). The bulk
of these payments came in the form of a check for $246,332.77,
which petitioner deposited into his bank account on Dec. 6, 1991.
A check for the December dividends in the amount of $565 was
issued to petitioner in January 1992.
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