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substantiation, that such interest could have been reported in
tax returns for prior taxable years. She did not produce any
evidence that her U.S. savings bonds were issued at a discount or
any evidence of an election under section 454. Petitioner’s son
indicated that, in preparing petitioner’s tax returns for the
1998 through 2000 taxable years, he did not report on her behalf
any of the $10,255 bond interest. Petitioner’s son also
acknowledged that he was uncertain about the reporting of
interest income on returns for years prior to 1998, which were
prepared by petitioner’s deceased husband.
Thus, even if it were appropriate to consider the reporting
of bond interest in prior years as an offset to the amount
required to be reported in 2000, there is nothing in this record
to support such a factual finding. Accordingly, we sustain
respondent’s determination that petitioner had unreported
interest income of $10,255 during the 2000 taxable year from the
redemption of U.S. savings bonds.
To reflect the foregoing, and as a result of our conclusion
that Social Security benefits received were $14,103, an amount
less than that determined by respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011