Tae M. & Young J. Kim - Page 12

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          for their taxable year 2002, or a total of $19,066.46 for that              
          year.  In support of that contention, petitioners rely on peti-             
          tioners’ 2002 amended return, in which petitioners claimed such             
          additional long-term capital losses.                                        
               A tax return is nothing more than a statement of a tax-                
          payer’s position and does not establish the existence or the                
          amount of any item shown therein.  See Wilkinson v. Commissioner,           
          71 T.C. 633, 639 (1979).                                                    
               On the record before us, we find that petitioners have                 
          failed to carry their burden of establishing that they have for             
          their taxable year 2002 long-term capital losses of $15,949.06 in           
          addition to the long-term capital loss of $3,117.40 claimed in              
          petitioners’ 2002 return.                                                   
          Interest From the U.S. Treasury                                             
               Respondent determined that petitioners have for the year at            
          issue $622 of interest income from the U.S. Treasury.  In his               
          direct testimony, petitioner Tae M. Kim (Mr. Kim) testified that            
          petitioners were unaware of any such interest.  On cross-examina-           
          tion, Mr. Kim conceded that petitioners received the respective             
          refund checks that the U.S. Treasury issued to petitioners with             
          respect to their taxable years 1997 and 1998.  The refund check             
          issued with respect to petitioners’ taxable year 1997 included              
          interest of $382.99, and the refund check with respect to their             
          taxable year 1998 included interest of $239.39.                             






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