Gary D. Myers - Page 7

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          includable in petitioner’s income for that year.  As previously             
          indicated, the fact that not all of that income was actually                
          distributed to petitioner in 2001 is of no consequence.                     
               In view of the foregoing, we hold for respondent on this               
          issue.                                                                      
          Conclusion                                                                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect our disposition of the disputed issue,                      


                                                  Decision will be                    
                                             entered for respondent.                  



























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