- 23 - Mr. Comey’s only argument is that these amounts are not his income, because he received them as Landtrak’s nominee. Amounts Received by Mr. Comey in 1992 On a Schedule B, Interest and Dividend Income, attached to his Form 1040 for 1992, Mr. Comey reported receiving $75 of interest and $16,024 of dividends. The dividends were paid by 18 of the 21 corporations that had paid dividends to Mr. Comey in 1991. On a Schedule D, Capital Gains and Losses, attached to his Form 1040 for 1992, Mr. Comey reported that he had received proceeds of $5,070 on the sale of the AT&T debenture. Although Mr. Comey reported the interest, dividends, and sale proceeds on the Schedules to his 1992 return, he did not include them in his income on the Form 1040. As he had done for 1991, Mr. Comey described these amounts as “nominee distribution[s]”. Mr. Comey reported total income of only $5,103 on his Form 1040 for 1992. In the notice to Mr. Comey for 1992, respondent determined that the $75 of interest and the $16,024 of dividends were Mr. Comey’s income. Respondent also determined that the $5,070 sale proceeds were taxable to Mr. Comey as capital gain. Mr. Comey admits that he received the $16,024 of dividends. He also has neither contested that he received the $75 of interest and the $5,070 proceeds, nor asserted that he isPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011