- 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 $131,879Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011