- 96 - entitled fall short of the additional unreported income noted above. Consequently, the interests of justice do not require that petitioner be permitted to raise new issues on brief. Interest Income Issue On his 1988 return, petitioner included $27,992 of interest income attributable to the ANB accounts. The ANB accounts were opened and maintained throughout 1988 and beyond under petitioner’s Social Security number. Petitioner obtained backup withholding tax credits in 1989, 1990, and 1991 for the ANB accounts. In an amendment to petition, petitioner alleged that the interest income should not be included in his income because the ANB accounts belonged to IL NA Tours, and therefore the corporation should have reported it. Petitioner contends that the ANB accounts were reflected as assets on IL NA Tours’ June 1988 financial statement and on its 1988 corporate return. Petitioner maintains that he had no power to control the ANB accounts after they were funded, he did not receive the interest, and the funds in the ANB accounts, including the interest earned on those funds, were not intended to benefit him. He further contends that money in the ANB accounts was used for IL NA Tours’ benefit and, ultimately, to pay its debts. Petitioner asserts that his accountant erroneously included the interest on petitioner’s return.Page: Previous 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 Next
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