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Respondent determined a deficiency of $2,666 in petitioners’
1997 Federal income tax. Due to the manner in which petitioners
presented their case, the sole issue we must decide is whether
petitioners are entitled to exclude disability benefits from
income under section 105(c).
This case was submitted fully stipulated pursuant to Rule
122. The limited facts stipulated are so found. Petitioners
resided in Maple Grove, Minnesota, at the time their petition was
filed.
It was determined that petitioner James K. Goodchild
(petitioner) had Crohn’s disease, arthritis in both knees, and
job-related stress. Respondent conceded that petitioner’s
medical condition prevented him from continuing as a senior
broadcast technician at the University of Minnesota. Petitioner
began receiving a disability benefit from the Minnesota State
Retirement System in April 1997.
During 1997, petitioners received $12,873 from the Minnesota
State Retirement System. The Minnesota State Retirement System
provided petitioners with a Form 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc., for that amount. During 1997,
petitioners received $6,030 from the Social Security
Administration. The Social Security Administration provided
petitioners with a Form 1099-SSA for that amount.
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Last modified: May 25, 2011