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relied on an IRPTR transcript6 of account reflecting receipt of
two Forms 1099 showing $5,400 each.
Petitioner credibly testified that the second Form 1099 was
a duplicate. At trial, petitioner accepted responsibility for
failing to file his Federal income tax returns and failing to
keep adequate records of the horse breeding activity. He agreed
to all omitted income, except the additional $5,400 reflected on
Form 1099. We conclude, on this record, that petitioner did not
receive additional other income of $5,400 as determined by
respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
6 The document is a Certificate of Official Record,
Information Returns Master File Transcript. Respondent was
unable to provide any detail as to the source of the $5,400
reflected in the transcript.
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