Tae M. & Young J. Kim - Page 4




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          ($622 interest determination), (3) $16 of income from the sale of           
          certain stock of a company described as “TRAVELERS PROP” ($16               
          Travelers Prop. determination), and (4) $8 of interest income               
          from Washington Savings Bank ($8 WSB interest determination).3              
          Respondent indicated in the 2002 notice that, in making the                 
          determinations in that notice to include such amounts in peti-              
          tioners’ gross income, respondent used the information set forth            
          in certain information returns that respondent required the                 
          payers of such amounts to provide to respondent and the taxpayer-           
          payees.  In the 2002 notice, respondent (1) summarized the                  
          information in each such information return pertaining to peti-             
          tioner Tae M. Kim (Mr. Kim) or to Ms. Kim and (2) included the              
          address of each payer and the account number for Mr. Kim or Ms.             
          Kim shown by each payer in each such return.                                
               In making the $21,267 gross proceeds determination in the              
          2002 notice, respondent relied on four Forms 1099-B, Proceeds               
          From Broker and Barter Exchange Transactions (Form 1099-B),4 that           
          EquiServe Inc. (EquiServe) provided, inter alia, to respondent              
          (EquiServe Forms 1099-B) with respect to Ms. Kim and that showed            


               3Petitioners reported $521.61 of interest income from                  
          Washington Savings Bank in Schedule B-Interest and Ordinary                 
          Dividends included as part of petitioners’ 2002 return.                     
               4The Court takes judicial notice that respondent requires              
          certain payers to use Form 1099-B in order to report, inter alia,           
          “Gross proceeds” or “Gross proceeds less commissions and option             
          premiums” from broker transactions.                                         





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