David C. Sylvester - Page 8




                                        - 8 -                                         
          not properly includable in the 1994 tax year because he did not             
          purchase any "stocks or bonds" until 1997.9                                 
               In this case, petitioner does not contest the amount of                
          income received from bond interest.  Petitioner's sole contention           
          is that the interest income was not includable in income for the            
          1994 tax year because he "thinks" that he did not purchase or own           
          any stocks or bonds until 1997.  Petitioner offered to provide              
          documentation of his contention to this Court, but failed to do             
          so.                                                                         
               Upon the basis of the record, we find that petitioner                  
          received $50 in gross income from A.G. Edwards for the 1994 tax             
          year.  Respondent is sustained on this issue.                               
          3.  Head-of-Household Status                                                
               Petitioner contends that his correct filing status is head             
          of household.                                                               
               Petitioner testified that his 13-year-old son lived with him           
          for the entire taxable year, and both parties have stipulated               
          that petitioner was unmarried at all times during 1994.                     
               Section 2(b) defines a head of household, in pertinent part,           
          as an individual who is not married as of the end of the tax year           
          and who maintains as his home a household which constitutes for             
          more than one-half of such taxable year the principal place of              
          abode of an unmarried son as a member of that household.                    

          9    Petitioner included the $50 in the $16,495 amount reported             
          on line 7 as Wages, salaries, tips, etc., on his 1994 income tax            
          return.                                                                     



Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011