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III. Careys
A. Deficiency in Tax
1. Attribution of Trust Income
a. Introduction
In making its return of income for 1995, the trust reported
gross receipts of $140,928 from its business of residential home
care and interest income of $112. Among the adjustments giving
rise to respondent’s determination of a deficiency in tax for the
trust for 1995 are an increase in gross receipts of $27,224 and
an increase in interest income of $174. On brief, the Careys
concede both adjustments. On the basis of the trust 1995 return
and those concessions, we find that, for 1995, the trust had
gross receipts from the business of residential home care of
$168,152 (the trust business gross receipts) and received
interest of $286 (the trust interest receipt).
With respect to the Carey 1995 return, respondent has
adjusted the gross income shown thereon by adding thereto both
the trust business gross receipts and the trust interest
receipt.4 In an attachment to the notice of deficiency issued to
4 On brief, respondent states that, if the Court sustains
those adjustments, respondent will concede that those amounts are
not gross income to the trust. Since we shall dismiss the trust
case for lack of jurisdiction, we need not concern ourselves with
that concession.
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