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effect at the time that the petition was filed.2 The decision to
be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax of $949 for the taxable year 2000.
After petitioners’ concessions,3 the sole issue for decision
is whether $7,8344 of interest income credited to petitioners’
bank accounts in 2000 constitutes gross income in that year.5 We
hold that it does.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioners resided
in Dayton, Washington.
During the year in issue, petitioners maintained a savings
2 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2000,
the taxable year in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
3 Petitioners concede respondent’s determinations
increasing their taxable dividends and increasing their taxable
pension and annuity benefits.
4 All amounts are rounded to the nearest dollar.
5 In the notice of deficiency, respondent determined that
petitioners failed to report $8,910 of interest income. The
parties stipulated, however, that the amount of interest income
in dispute is $7,834.
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