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Scrap metal Amount reported Unreported
Year proceeds on amended return income determined
1989 $21,258 $11,353 $9,905
1991 76,550 41,819 34,731
OPINION
Unreported Income
The first issue is whether John had unreported income in the
amounts determined by respondent. The parties have stipulated
that Simco sold scrap metal in exchange for the proceeds
specified above during the years at issue and that such proceeds
were retained by John. Simco reported as income on its amended
returns a significant portion of those proceeds. Simco concedes
on brief that the balances of the proceeds not reported on
Simco’s amended returns, $8,521 in fiscal year 1990 and $860 in
fiscal year 1991, are unreported income as determined by
respondent. With respect to John, for tax year 1989 petitioners
present no argument as to the unreported income determined by
respondent, and we treat the issue as conceded. With respect to
John’s 1991 tax year, petitioners argue that the proceeds he
retained from the sale of scrap metal from July 1, 1991 through
December 31, 1991 (the first half of Simco’s fiscal year ended
June 30, 1992) represent repayment by Simco of money that John
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