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appropriately in light of the fact that the error appearing on
petitioners' return was clearly a mathematical mistake.
Consequently, respondent did not err by issuing petitioners
a refund and subsequently determining a deficiency (and notably,
a deficiency arising out of an unrelated issue5) for the same
taxable year.
In light of the foregoing, petitioners must report on their
joint return the $1,640 of wage income received by petitioner
wife.
To reflect our disposition of the disputed issue,
Decision will be entered
for respondent.
5 As a response to petitioners' claims of injustice, we
note that the mathematical error detected by respondent was
unrelated to respondent's determination regarding the unreported
wage income. Petitioners would be liable for the tax on the
unreported income even if respondent had failed to detect the
mathematical error and had failed to refund petitioners the
additional $1,352 amount. There can be no dispute that
petitioners only benefited from the summary manner in which
respondent detected the mathematical error and processed
petitioners' additional refund.
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Last modified: May 25, 2011