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B. Interest Income
Petitioners admitted at trial that they received a refund
check from respondent in 1997 and that such check pertained to
the taxable year 1993. However, petitioners contend that they
did not receive any interest. In this regard, petitioners rely
on that part of the respondent’s notice dated October 6, 1997,
stating: “Amount Of Interest You Earned on Overpayment ...
$.00". According to petitioners, this statement demonstrates
that they neither received nor were credited with any interest on
their 1993 overpayment of income tax. We disagree.
Petitioners read the notice dated October 6, 1997,
myopically. That notice clearly states that in addition to the
$351.59 of tax that petitioners would receive as a refund, “Any
Interest Due You Will Be Added”. In that regard, the record
clearly demonstrates that respondent did, in fact, “add” interest
to petitioners’ refund, specifically $311.84, which was part of
the $663.43 check that was issued on or about October 6, 1997.
Accordingly, we hold that petitioners failed to report interest
income in the amount of $311.84. Respondent’s determination is
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
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