Kim Anthony Polonczyk - Page 6

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          Workforce falls below the minimum income level for 2002 filing              
          * * * of $7,700.”                                                           
               Petitioner’s argument that he did not have enough income to            
          file a return in 2002 has no merit.  Without regard to the $4,466           
          of unemployment compensation, petitioner had $15,227.70 of IRA              
          distribution income, making it necessary to file a return in that           
          year.  He was obligated to report all of his income on that                 
          return, including unemployment compensation received.                       
          Accordingly, respondent’s determination as to this amount is                
          sustained.                                                                  
          Interest Income and Farmers Distribution                                    
               Section 6201(d) provides that, if the taxpayer in a court              
          proceeding asserts a reasonable dispute with respect to the                 
          income reported on an information return and fully cooperates               
          with the Commissioner, the Commissioner shall have the burden of            
          producing reasonable and probative information in addition to the           
          information return.                                                         
               Petitioner filed a Form 1040 in which he did not report the            
          $13 of interest income from the credit union.  Petitioner                   
          testified that the average balance in his checking account was              
          around $142 and that the average balance in his savings account             
          was around $25.  Petitioner disputed that his checking account              
          could have earned $13 of interest income in 1 year.  The records            
          presented at trial showed returned draft fees that apparently               






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