- 2 - In separate notices of deficiency, respondent determined deficiencies of $1,552 and $1,515 in petitioners' Federal income taxes for 1996 and 1997, respectively. The sole issue for decision is whether certain payments by insurance companies during the years at issue of indebtedness owing by petitioners on credit cards constitute gross income under section 61(a).2 Some of the facts were stipulated. Those facts and the accompanying exhibits are so found and are incorporated herein by reference. Petitioners' legal residence at the time the petitions were filed was San Diego, California. During the years at issue, petitioners had several credit cards that had been issued by various banks. Petitioners availed themselves of the opportunity to purchase credit card insurance that provided for the payment of portions of indebtedness owing on the credit cards in the event of death, disability, or unemployment. All indebtedness on the credit cards provided for the accrual of interest in the event amounts due on each card were not paid timely. In addition, the premiums for the credit card insurance were charged to each credit card. 2 Other adjustments were made to petitioners' Schedules A, Itemized Deductions, some of which are computational and will be resolved by the Court's holding on the matter at issue. All other adjustments that are not computational were conceded by petitioners.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011