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or was expended for the purpose designated and that petitioner
had not substantiated the amount.
Additional Business Income
In the notice of deficiency, respondent determined that
during 1989 petitioner received business income of $1,085 from a
litigation matter, which petitioners failed to include on their
return for that year. Respondent increased petitioner’s income
accordingly.
Income From Prizes
During November 1989, petitioner won a laptop computer from
JMS Inc., d.b.a. Computerland (Computerland). Petitioner,
however, did not want the computer and refused to accept it.
Instead of the computer, Computerland gave petitioner a store
credit. Petitioners did not include any income attributable to
the Computerland prize on their Federal income tax return for
1989. In the notice of deficiency, respondent determined that
during 1989 petitioners received income attributable to the
Computerland prize of $2,223. Respondent increased petitioners’
income for that year accordingly.
Dividend Income
Respondent determined that for 1992 petitioners overstated
income from dividends by $8,732. Respondent reduced petitioners’
income for that year accordingly.
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