- 6 - The third issue for decision is whether petitioners received but did not report dividend income. Respondent determined that petitioners failed to report $772 in dividend income from Charles Schwab.2 Gross income generally includes income from whatever source derived, including dividends. See sec. 61(a)(7); sec. 301(c)(1). Petitioners do not deny receiving the $772 of dividend income from Charles Schwab. Rather, Mr. Kuo testified that the dividend income was reported on the Schedule C as gross receipts (the remainder of the reported $1,720 in gross receipts was purportedly a mistake and not income). We find this testimony to be incredible; we do not believe that petitioners reported dividend income as the sole income from their computer-related business, and that in the process they somehow mistakenly entered $1,720 instead of $772. We uphold respondent’s determination that petitioners received $772 in unreported income. The final issue for decision is whether petitioners are liable for an accuracy-related penalty under section 6662(a). Respondent determined that petitioners are liable for an accuracy-related penalty imposed by section 6662(a) for the portion of the underpayment of tax for 1996 attributable to 2Respondent concedes the following amounts reflected in the notice of deficiency as unreported income: $221 of dividends and $3 of interest from Herzog Geduld, and $200 of dividends and $1 of interest from E Trade Securities. Petitioners concede receiving unreported interest income of $33 from Summit Bank.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011