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notice of deficiency, which petitioner thereafter received,
attributed the $31,980 in interest as income to him. That income
is the principal issue in this case.
The parties agree that, for the years in which petitioner’s
mother held the bonds, her income was minimal, and she did not
file Federal income tax returns. Thus, income tax on the bond
interest was never paid.
Shortly after petitioner received the notice of deficiency,
he prepared, for the 2001 tax year, a Federal income tax return
in the name of his mother, on which he reported the $31,980 as
interest income. The tax shown on that return was $11,598, which
included tax on the $31,980 in interest on the bonds. He mailed
the return to the IRS and included a check of $11,598. The
return was not accepted by the IRS for the reason that
petitioner’s mother died in 1999 and, therefore, was not a
taxpayer in 2001. The $11,598 check petitioner sent with the
return was not returned to him, nor was petitioner refunded that
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