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Service (IRS) and issued petitioner information returns3 as
follows:
Issuer Reporting form Amount
American Security 1099-C $11,396.09
Capital One Bank 1099-MISC, Box 7 $4,448.00
TOTAL $15,844.09
However, at trial respondent produced evidence to substantiate
payments from American Security of only $10,800. Respondent’s
counsel admitted that he did not know how the amount of $11,3964
was calculated by American Security. Therefore, respondent
conceded the difference in payments of $596. As a result,
$15,248 is the total amount of unreported income remaining at
issue. Petitioner did not include these amounts as income in his
Federal income tax return for 2001. In the notice of deficiency,
respondent determined that these amounts constituted gross
income.
3Petitioner claims that he did not receive the applicable
Forms 1099; however, petitioner admitted that he was aware that
such payments were being made during tax year 2001.
4Amount rounded to the nearest dollar.
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Last modified: May 25, 2011