118 T.C. No. 24
UNITED STATES TAX COURT
THOMAS WILLIAM MCADAMS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12763-00. Filed May 15, 2002.
P married his wife (W) in 1947. P and W were not
legally separated or divorced. During 1998, W resided
in Boise, Idaho (Boise address). During 1998, P stayed
at the Boise address in excess of 30 days. P and W
maintained separate bedrooms at the Boise address.
In 1998, P received $11,181.60 in Social Security
income. P filled out the Social Security Benefits
Worksheet associated with his 1998 tax return. P
listed $25,000 as his “base amount” because he was
married and believed that he lived apart from W for the
entire year. On his 1998 tax return, P claimed
“married filing separately” status, reported $11,181.60
of Social Security benefits, and reported $0 as the
taxable amount of his Social Security benefits.
In the notice of deficiency, R increased P’s
interest income by $52 and reduced P’s “base amount” to
zero, thereby increasing the taxable amount of P’s
Social Security benefits.
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