Khen Thi and Hong Van Huynh - Page 3




                                        - 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.                                                                




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