- 2 -
income on such refund received in 1999 but not reported on their
1999 tax return.
Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code, as amended.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Staten Island, New York.
Petitioners filed their 1998 tax return with the filing
status of “Married filing joint return”. On their Schedule A,
Itemized Deductions, petitioners claimed $18,497 for State and
local income taxes paid in 1998.
During 1999, petitioners received a refund of $14,984 of the
amount paid on their 1998 State income taxes and interest income
on the refund of $149.35.
Petitioners filed their 1999 tax return with the filing
status of “Married filing joint return”. Petitioners did not
report any income for “Taxable refunds, credits, or offsets of
state and local income taxes”. Petitioners excluded $236,761
from gross income. Attached to the 1999 tax return is a letter
dated January 31, 2000, which states:
This letter is to confirm that Edgar B. Alacan, as an
employee of J.W. Barclay & Co., sustained $236,761 in after
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011