Johnnie Everage - Page 2

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               Respondent determined a deficiency in petitioner's 1994                
          Federal income tax in the amount of $1,820.  Petitioner resided             
          in Milwaukee, Wisconsin, at the time the petition was filed.                
               The only issue is whether Social Security benefits received            
          by petitioner in 1994 in the amount of $6,511 are includable in             
          gross income.                                                               
               The facts may be summarized as follows.  Petitioner was                
          employed by the U.S. Postal Service until 1988.  In that year, he           
          was retired.  Petitioner did not receive a pension at that time.            
          In 1991, petitioner started drawing Social Security benefits.  In           
          1994, petitioner was awarded a pension from the Postal Service              
          and received a lump-sum payment in the amount of $34,853 for his            
          pension from 1988.  During 1994, petitioner also received $7,909            
          in Social Security benefits.                                                
               On his 1994 Federal income tax return, petitioner reported             
          the $34,853 received from the Postal Service.  He did not report            
          any income from the Social Security Administration.  Upon                   
          examination of that return, respondent determined that $6,511 of            
          the Social Security benefits should have been included in gross             
          income.                                                                     
               Petitioner and respondent agree that petitioner received               
          $34,853 from the Postal Service and that of that amount $33,053             
          is includable in gross income.  Petitioner does not dispute that            
          he received $7,909 from the Social Security Administration, but             






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