Cristeen B. Comey - Page 23




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               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 is                   





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