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on the sale of the shares would still be included in Mrs. Comey’s
income, because Landtrak is disregarded for tax purposes.
For all the foregoing reasons, we hold that Mrs. Comey’s
1991 income includes the $90,788 capital gain realized on the
sale of the Capital Fund shares, as determined by respondent.
2. Mr. Comey’s Income for 1991 and 1992
Mr. Comey’s address was in Winnetka, Illinois, when his
petition was filed. Mr. Comey filed his Federal income tax
return (Form 1040) for 1991 on June 28, 1993. He filed his
return for 1992 on August 4, 1993.
Amounts Received by Mr. Comey in 1991
On a Schedule B, Interest and Dividend Income, attached to
his Form 1040 for 1991, Mr. Comey reported receiving $438 of
interest paid with respect to an AT&T debenture. Mr. Comey also
reported receiving $28,056 of dividends paid with respect to the
stock of 21 corporations.7 Mr. Comey had inherited much of this
stock upon the death of his father, Aubrey Comey, in 1967.
On a Schedule D, Capital Gains and Losses, attached to his
Form 1040 for 1991, Mr. Comey reported receiving proceeds of
$9,596 on the sale of stock in two corporations.
7 The corporations were American Express, Ameritech, Asarco,
AT&T, Bell Atlantic, Bellsouth, Bethlehem Steel, Comsat, DQE,
Exxon, GTE, Illinois Power, Northern States Power, Nynex,
Oklahoma Gas & Electric, Outboard Marine, Pacific Gas & Electric,
Pacific Telesis, Robbins & Meyers, Southwestern Bell, and US
West.
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