- 8 -
no bearing on the legal issues raised in this case, the Court
will nevertheless address this briefly.
In general, with respect to any amount required to be shown
on a form prescribed for any internal revenue return, statement,
or other document, the fractional part of a dollar is disregarded
unless it amounts to one-half dollar or more, in which case, the
amount is increased by $1. Sec. 6102(a). For example, $18.49 is
rounded to $18; $18.50 is rounded to $19; $18.51 is rounded to
$19. See sec. 301.6102-1(a), Proced. & Admin. Regs. Rounding
does not apply to items which must be taken into account in
computing the amount that must be reported on a return,
statement, or other documents. Sec. 6102(c). Rounding applies
only to the final amount. Id.
While petitioner does not dispute that respondent has the
authority to round amounts that have cents into whole-dollar
amounts, he questions whether respondent has consistently and
fairly applied these rounding rules. In support of his
contention, petitioner presented a copy of the explanation of
proposed changes that was attached to the notice of deficiency.
Petitioner asserts that the miscellaneous deduction for the joint
return is $1,703.57 but in the explanation, respondent rounded
the amount down to $1,703 instead of up to $1,704. Petitioner
further asserts that the joint taxable income is $131,878.41, but
in the explanation, respondent rounded the amount up to $131,879
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011