Steven K. Han - Page 105





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          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.                   






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