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disability as provided by the New York City Employees' Retirement
System.
On his 1990 U.S. Individual Income Tax Return, petitioner
did not include in income the $23,032 New York City pension
payments received that year. The IRS sent petitioner an
Information Request inquiring why his 1990 return did not include
the New York 1990 pension income in the amount of $23,032
reported by the New York City Comptroller. By letter dated March
30, 1993, petitioner responded to that inquiry, attaching a copy
of his Report of Discharge from the armed services, a copy of the
Veterans Administration's letter granting him Individual
Unemployability, and a letter from the New York City Employees'
Retirement System granting him ordinary disability retirement.
After submitting the foregoing letter, petitioner received a
"closing letter" from respondent dated May 7, 1993, which
accepted petitioner's 1990 return as filed.
The Commissioner's determination of deficiency for 1992 was
based upon two adjustments:
a. The inclusion in gross income of the $23,094 pension
received in 1992 by petitioner from New York City.
b. The inclusion in gross income of a portion ($3,181) of
the $14,073 in benefits he received from the Social
Security Administration in 1992.
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