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Gross income includes compensation for services. Sec.
61(a)(1). In the present case, decedent received wages of $4,719
from Mangione Enterprises of Turf Valley, and he did not report
such amount in his 2000 return. Accordingly, we sustain
respondent’s determination that decedent received unreported
income of $4,719 from wages in 2000.
Gross income also includes interest. Sec. 61(a)(4). In the
present case, decedent was credited with interest income of
$7,435 in 2000 from custodial accounts established pursuant to
the Maryland Uniform Transfers to Minors Act (MUTMA). Under the
MUTMA, interest income constitutes “custodial property” that
generally transfers to a minor when he or she attains the age of
either 18 years or 21 years, depending upon who originally
transferred such property to the custodian.3 See Md. Code Ann.,
Est. & Trusts secs. 13-301(f), 13-320 (2001). While decedent was
only 17 in 2000, he enjoyed the economic benefit of interest
income from the custodial accounts, and therefore, such interest
is taxable in the year earned and not in the year of actual
receipt by him.4 See Anastasio v. Commissioner, 67 T.C. 814,
3 If a minor dies before attaining the requisite age, the
custodial property transfers to the minor’s estate upon the
minor’s death. Md. Code Ann., Est. & Trusts sec. 13-320(3)
(LEXIS through 2003 Sess.).
4 A minor who has attained the age of 14 years may seek a
court order for delivery and payment of so much of the custodial
property for the minor’s use and benefit. Md. Code Ann., Est. &
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