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The “Dispute”
On his 1981 tax return, petitioner reported $10,513 as
income on a Schedule C under the business name Project
Identification Team. The parties’ stipulations include the
following:
15. For 1981, the petitioner received interest income
in the amount of $11,219 from Fidelity Investments.
16. For 1981, the petitioner reported as gross
receipts on his 1981 tax return, Schedule C, $10,513 of the
$11,219 interest income which he received from Fidelity
Investments.
17. For 1981, the petitioner did not report anywhere
on his 1981 tax return the remaining $706 [$11,219 - $10,513
= $706] in interest income received from Fidelity
Investments.
* * * * * * *
30. For 1981, the $10,513 reported by petitioner on
his 1981 Schedule C as gross receipts was actually interest
income.
* * * * * * *
35. For 1982, the petitioner received $12,298 in
interest income from Fidelity Investments.
OPINION
Petitioner contends that certain income from Fidelity
Investments ($10,513 for 1981, $12,298 for 1982) should be
treated as Schedule C business income rather than Schedule B
nonbusiness interest income.
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Last modified: May 25, 2011