- 21 -
gross income. Petitioner objected to respondent’s assertion that
he received taxable interest income of $972 in 2002 on the
interest-bearing escrow account with Quadrino & Schwartz. The
stipulated schedule of the escrow balance shows that interest of
$3,186.49 was earned on the account and was reflected in the
February 14, 2005, payment made to petitioner. Respondent
asserts that $972 of that amount is attributable to 2002.
Petitioner has failed to present any reasonable dispute with
respect to respondent’s assertion. In these circumstances,
respondent was entitled to rely on third-party information. See
sec. 6201(d); Parker v. Commissioner, 117 F.3d 785 (5th Cir.
1997); Silver v. Commissioner, T.C. Memo. 2005-281. Petitioner
also objected to respondent’s assertion that petitioner received
$15 of taxable interest income for savings bonds in 2002. The
earned interest of $972 and $15 in 2002 was deemed admitted
pursuant to Rule 90 when petitioner failed to respond to the
request for admissions. Therefore, petitioner has taxable
interest income of $987 for 2002.
Credits, Exemptions, and Deductions
Petitioner argues that he is entitled to dependency
exemptions for his wife and three children under sections 151 and
152 and to the child tax credit under section 24. Petitioner
belatedly made these claims and was afforded the opportunity to
file a motion to amend the petition; however, the proposed
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: May 25, 2011