- 6 -
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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Last modified: May 25, 2011