Roger G. and Lilianne J. G. Maki - Page 2

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               Respondent determined a deficiency in petitioners' 1991                
          Federal income tax in the amount of $882 and an accuracy-related            
          penalty pursuant to section 6662(a) in the amount of $176.                  
               The issues for decision are:  (1) Whether $3,150 of Social             
          Security disability benefits received by petitioners during 1991            
          constitutes gross income; and (2) whether petitioners are liable            
          for the accuracy-related penalty pursuant to section 6662(a).               
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in Des Moines,               
          Washington, on the date the petition was filed in this case.                
          Hereinafter, references to petitioner in the singular are to                
          petitioner Roger G. Maki.                                                   
               In 1991, petitioner received Social Security disability                
          benefits in the amount of $6,299.  On their 1991 Federal income             
          tax return, petitioners identified this amount as "Social                   
          Security benefits" with an added notation "Disability payments              
          see enclosure" on line 21a of the return; however, the amount was           
          not entered as taxable income on the adjacent line 21b of                   
          petitioners' income tax return.  Petitioners' adjusted gross                
          income for 1991, without the inclusion of the Social Security               
          disability benefits, was $53,321.                                           
               Petitioner contends that his Social Security disability                
          benefits are not taxable.  Petitioner's position is based on Form           






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