William H. and Sandra G. Flank - Page 9

                                        - 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