- 3 - totaling $415,266. Of that amount, $414,130 represented proceeds from the annuity contract, while $1,136 represented interest that accrued before the proceeds were distributed. At Mr. Falcon’s behest, each check was deposited into a joint bank account in the names of petitioner and Ms. Becquer. Petitioner and Ms. Becquer had signature authority over the joint account.2 In August 2003, petitioner wrote a check from the account to her father in the amount of $415,000. In 2004, Travelers issued petitioner a Form 1099-R, Distributions from Pensions, Annuities, Retirement or Profit- Sharing Plans, IRAs, Insurance Contracts, etc., listing a gross distribution of $414,130 and a taxable amount of $53,886. Travelers also issued petitioner a Form 1099-INT, Interest Income, listing taxable interest income of $1,136. Petitioners did not report any portion of the annuity proceeds or interest income on their joint 2003 tax return. Respondent issued petitioners a notice of deficiency in August 2005. Respondent determined that petitioners must include in gross income $53,885 of the annuity proceeds and $1,136 of interest income. Respondent also determined an accuracy-related 2 Ms. Becquer separately received and deposited into the joint account proceeds from Mrs. Knight’s annuity contract. Those proceeds are not at issue in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007