- 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 proposedPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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