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payments consist of 14.49 percent of the total amount received.
Applying this percentage to the amounts received by petitioner in
1996, we conclude petitioner received $4,976 in Tier II payments
($34,341 x 14.49% = $4,976). Subtracting from this amount $782
for contributions made by petitioner, we conclude petitioner
received $4,194 in taxable Tier II benefits in 1996, and
respondent is sustained on this issue to the extent of $4,194.
II. Dividend and Interest Income
The next issue for decision is whether petitioners were
required to include in income dividends and interest received in
1996. Gross income includes all income from whatever source
derived, including interest and dividends. See sec. 61(a)(4),
(7). It is not entirely clear from this record whether
petitioners dispute the omitted dividend and interest income
issue. Since no evidence was presented by petitioners, we
sustain respondent on this issue. See Rule 142(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011