Eric B. Benson, et al. - Page 32

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          calculation of the Bensons’ interest income reduces the total               
          interest income by $4 of interest received from Baden Spiel Haus            
          and $411 of interest received from the Evelyn Hermsmeir                     
          partnership.  We agree with respondent’s calculation.  The                  
          Bensons’ reported gross income includes income that they received           
          from the Baden Spiel Haus and Evelyn Hermsmeir partnerships.  If            
          their interest income were not reduced by the amount of interest            
          income received from these two partnerships, the Bensons’                   
          reported gross income would include this interest income twice.             
          We find that the Bensons’ reported interest income of $6,690 for            
          1994.                                                                       
               On brief, the Bensons assert that they reported dividend               
          income of $29,327 in 1994.17  Respondent calculated the Bensons’            
          reported dividend income as totaling $62,748 and reduced this               
          amount by $62,735, which represents the amount of dividend income           
          that the Bensons received from NPI.  Because their share of NPI             
          income will be calculated separately, including the NPI dividend            
          income as a portion of the Bensons’ dividend income would include           
          this item twice.  We agree with respondent and find that the                
          Bensons reported dividend income of $13 in 1994.                            
               As with the dividend income, the parties dispute the                   
          Bensons’ reported royalty income.  The Bensons calculated their             

               17 The Bensons’ 1994 return reports a taxable refund of                
          $29,327.  It appears that they mistakenly listed the reported               
          taxable refund as a dividend.                                               





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