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income” to be the taxpayer’s adjusted gross income with certain
amounts disregarded and certain amounts included.
In the present case, we conclude that petitioner’s modified
adjusted gross income would not be higher than that of Ms.
Rodriguez, given that her wage income alone was greater than
petitioner’s total income for 2001. Accordingly, we sustain
respondent’s determination on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011