George R. and Donelle C. Hawthorne - Page 9




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          the only witness.  We found Mr. Hawthorne's testimony to be                  
          general, conclusory, and/or vague in certain material respects.              
          Before turning to the various issues presented, we note that we              
          have considered all of petitioners' arguments that are not                   
          discussed herein and find them to be without merit.                          
          Cash Distributions on Certain Stock                                          
               Petitioners reported as dividend income (1) in their return             
          for 1992 all cash distributions that Mr. Hawthorne received from             
          Gulf States during that year and (2) in their return for 1993 all            
          cash distributions that he received from Centerior Energy and                
          from Portland General during that year.  With respect to the cash            
          distributions that Mr. Hawthorne received during 1992 from Gulf              
          States, petitioners contend that those distributions are liqui-              
          dating distributions, and not dividends.  With respect to $609.91            
          of the cash distributions totaling $1,440 that Mr. Hawthorne                 
          received from Centerior Energy and all of the cash distributions             
          that he received from Portland General during 1993, petitioners              
          contend that those distributions do not constitute dividend, or              
          any other kind of, income.  That is because, according to peti-              
          tioners, the respective payors of those cash distributions                   
          reported them in corrected Forms 1099-DIV as nontaxable distribu-            
          tions.                                                                       
               Turning first to the cash distributions that Mr. Hawthorne              
          received from Gulf States during 1992 on the shares of preferred             
          stock that he owned in that company, the record establishes that             
          Gulf States reported those distributions in Form 1099-DIV as                 


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