Richard L. and Betty L. Seltzer - Page 6

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          previously taxed income to OPM in an amount totaling $13,844.907                   
          between the years 1983 and 1989.  Petitioners contend that the                     
          reductions in some manner relate to these alleged repayments or                    
          contributions and that unless the reductions are allowed portions                  
          of petitioner's retirement benefits will effectively have been                     
          taxed twice.  Secondly, they argue that they are entitled to                       
          reduce the amount received from OPM for each year by the amount                    
          that petitioner should have received for such year if OPM would                    
          have properly computed his CSRS retirement benefits.                               
                While we agree, as respondent apparently does, that as a                     
          general proposition taxpayers should not be twice taxed on the                     
          same income, we fail to see any relationship between the amount                    
          that petitioner claims to have repaid to OPM during 1983 through                   
          1989, and the amount by which petitioners reduced the CSRS                         
          retirement benefits for each year.  In any event, we find that                     
          with respect to the years before us, the only repayment made by                    
          petitioner occurred in 1989, and the amount of such repayment was                  
          taken into account in the amount of gross annuity distributions                    
          reported on the Form W2-P(A) issued to petitioner for that year.                   
          There is no evidence in the record of any repayments with respect                  
          to the years 1990 or 1991.  We believe petitioner considers the                    
          term "repayment" to include amounts that he should have received                   

          7Specifically, petitioner asserts that he repaid or                                
          contributed income to OPM in the amounts of $152, $1,295.16,                       
          $2,562.84, $3,354.26, $2,430.24, $2,430.24, and $1,620.16 for the                  
          years 1983 through 1989, respectively.                                             




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