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$241 is the interest on $30,000 for 42 days. Petitioner claimed
he was “an accrual basis taxpayer” and that he should report the
interest when it was earned rather than when he received it.
The amount of any item of gross income shall be included in
the gross income for the taxable year in which it is received by
the taxpayer unless under the method of accounting used by the
taxpayer the amount is properly accounted for as of a different
period. Sec. 451(a). Petitioner presented no credible evidence
that he used the accrual method of accounting. Additionally,
petitioner testified that in previous years he reported interest
income as he received it and as it was reported to him on Forms
1099-INT, Interest Income. Furthermore, petitioner failed to
report any interest from Bank One on his 2001 return.
Petitioner was vague, absentminded, and nonresponsive when
answering certain questions about the Bank One CDs. Despite
having clear memories of events from the 1980s and 1990s and the
exact maturity date of the Bank One CDs, petitioner claimed
memory loss as to the amount he received in 2001 from the Bank
One CDs. He was unwilling to admit or deny whether he received
the interest from the Bank One CDs in 2001, even though he signed
the stipulation of facts on the day of trial stipulating he
received $2,301 in interest from Bank One in 2001.
Under the circumstances, we are not required to, and
generally do not, rely on petitioner’s testimony to sustain his
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