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$16,798 adjustment for Unreported Income--Casino.
Respondent did not make a corresponding subtraction of the
1991 $9,880 adjustment for Unreported Income--Casino in
arriving at the 1991 Other Unreported Income. Neither side
has sought to explain, justify, or attack this substantial
difference between the 1991 and 1992 procedures. We leave
the parties as we find them on this matter. See, e.g.,
Thomas v. Commissioner, 92 T.C. 206, 232 (1989), and cases
there cited.
6 This amount includes the $90 by which petitioners overstated
their Forms W-2 income on their 1993 tax return. See infra
table 3, note 2.
7 This amount is $600 less than the amount of the 1993 $10,618
notice of deficiency adjustment for Other Unreported Income.
On brief, respondent asks us to find that the correct amount
of this adjustment is $10,010, which is $608 less than the
notice of deficiency adjustment. It may be that this
discrepancy is what led to respondent’s concession (see
supra note 2) in the answer that the deficiency is $168 less
than the amount determined in the notice of deficiency, and
that the negligence addition to tax is $34 less than the
amount determined in the notice of deficiency. Also, there
is a $1 difference between the $10,018 “excess deposits” and
the sum of the amounts in the 1993 column; we assume that
this difference arises from rounding the amounts to the
nearest dollar. The parties are directed to resolve this
matter in the computation under Rule 155.
F. Tax Returns
On their tax returns for the years in issue, petitioners
reported income and total tax as shown in table 3.
Table 3
Item 1991 1992 1993
l.7--Wages, etc. (Form W-2) $57,945 1$62,339 2$71,237
l.8--Interest 129 675 218
l.9--Dividends 18 -- 9
l.10--Taxable refunds -- -- 136
l.13--Capital gain or (loss) -- (3,000) 314
l.17--Pensions and annuities 16,413 16,576 17,281
l.18--Rents, etc. (5,081) (3,899) (6,122)
l.23--Total income 69,424 72,691 82,773
l.53--Total tax 7,333 7,362 9,224
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