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86(a).4 Section 86(b)(1) provides that married taxpayers filing
joint returns whose modified adjusted gross income (plus one-half
of their Social Security benefits) exceeds $32,000 must include
in income the lesser of: (1) One-half of their Social Security
benefits, or (2) one-half of the excess of their modified
adjusted gross income over $32,000. Because we have previously
found various increases to petitioner's gross income for the
taxable year 1986, we find that petitioner is required to include
$4,095 of the Social Security benefits in income. Sec. 86.
Accordingly, we sustain respondent's determination with respect
to this issue.
Issue 4. Unreported Agricultural Subsidy Payments
Respondent determined that during the years 1987 and 1988,
petitioner and his spouse, or their agent, FNB, received ASCS
payments in the amounts of $11,198.96 and $11,298, respectively.
Petitioner and his spouse did not report these ASCS payments on
4Sec. 86(a) provides:
Gross income for the taxable year of any taxpayer described
in subsection (b) * * * includes social security benefits in
an amount equal to the lesser of
(1) one-half of the social security benefits
received during the taxable year, or
(2) one-half of the excess described in subsection
(b)(1).
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