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On the 1994 joint Federal income tax return that he and his
late wife filed, petitioner reported taxable interest income of
$6,085 and tax-exempt interest income of $28,635.2 Respondent
determined that the interest income petitioner received from the
redemption of tax certificates was not tax exempt. Respondent
further determined that petitioner failed to report interest
income of $7,482. This amount represents interest reported on
Forms 1099, which listed copayees’ Social Security numbers.
Respondent also determined that petitioner failed to report
interest income from First Union National Bank of $99 and
interest income from Bankers Trust of $6. Accordingly,
respondent determined that petitioner failed to report taxable
interest income of $36,221.
In the present case, petitioner concedes $28,739 of the
$36,221 interest income adjustment contained in the notice of
deficiency. The interest income from First Union National Bank
and Bankers Trust is not disputed by petitioner. Petitioner also
does not argue that the interest income reported on the Forms
1099 issued by the tax collector is tax exempt. Instead,
petitioner contends that the interest income represented by Forms
1099 listing copayees’ Social Security numbers should not be
2 In the deficiency notice respondent determined that the
amount should have been $28,634, apparently because of an
arithmetic error.
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Last modified: May 25, 2011