N. Thomas Ryan - Page 22

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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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