Olin E. Gibson and Zora M. Gibson - Page 3

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          States, 847 F.2d 1279 (7th Cir. 1988); Bradley v. Commissioner,             
          T.C. Memo. 1991-578.                                                        
               Based on the sparse record in this case, we find that                  
          petitioners received tier 1 and tier 2 benefits during 1991 in              
          the respective amounts of $4,122 and $9,262 which they failed to            
          report as taxable income on their Federal income tax return.                
          Respondent's determination of deficiency is sustained.2                     
                                                  Decision will be entered            
                                             under Rule 155.                          























               2Respondent has acknowledged that tier 1 and tier 2 benefits           
          receive different tax treatment under the provisions of secs. 86            
          and 72(r).  This difference was not reflected in the notice of              
          deficiency and necessitates a Rule 155 computation in this                  
          matter.                                                                     



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