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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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