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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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Last modified: May 25, 2011