Cliff Connors - Page 21

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          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                  

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