- 21 - D. Interest Income Under section 61, interest income is includable in income. See sec. 61(a)(4). Respondent determined that during 1987, 1988, 1989, and 1990, petitioner received interest income in amounts that exceeded what was reflected on his tax returns. Petitioner admitted that he did not reflect interest income received from Faust Daniels for the 1988 and 1989 tax years. Petitioner, however, alleged that some of the interest income that he failed to reflect was actually included in the gross receipts of his law practice. Petitioner further alleged that his secretary inadvertently included the entire payment--principal and interest--as taxable income, and therefore his income was overstated. As an initial matter, we note that petitioner has failed to present any evidence that interest income was actually reported on Schedule C. If, however, interest income was reported on Schedule C, a separate adjustment for interest income could result in petitioner’s being taxed twice on the same income. Respondent’s method of computing petitioner’s correct Schedule C income, however, eliminated the possibility of such duplication by subtracting interest income from the computation of law practice income. We further note that the only evidence that both principal and interest were included in taxable income isPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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