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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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