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(1) Whether petitioner’s unemployment compensation is
taxable under section 85;
(2) whether petitioner had interest income from his checking
account with Forth Worth City Credit Union; and
(3) whether petitioner had taxable income from a Farmers New
World Life Insurance Co. distribution.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in San Antonio, Texas, at the time that he
filed his petition.
On April 15, 2003, petitioner timely filed Form 1040, U.S.
Individual Income Tax Return, for the income tax year 2002.
Petitioner reported $15,227.70 of IRA distributions and
$11,037.30 of itemized deductions on the Form 1040. Petitioner
did not report any other income for 2002.
On May 17, 2004, the Internal Revenue Service (IRS) sent to
petitioner a statutory notice of deficiency for $1,400 for 2002.
The IRS determined that petitioner did not report $4,466 of
unemployment income from the Texas Workforce Commission (Texas
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