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(ii) does not live apart from his
spouse at all times during the taxable year.
(2) Adjusted base amount.--The term “adjusted
base amount” means--
(A) except as otherwise provided in this
paragraph, $34,000,
(B) $44,000 in the case of a joint return,
and
(C) zero in the case of a taxpayer described
in paragraph (1)(C).
Petitioner's adjusted gross income and modified adjusted
gross income are the same--$33,053. His "base amount" was
$25,000. Sec. 86(c)(1)(A). His "adjusted base amount" is
$34,000. Sec. 86(c)(2)(A). Under section 86(b)(1) petitioner's
modified adjusted gross income ($33,053) plus one-half of the
Social Security benefits ($3,955) totaling $37,008 exceeds the
"adjusted base amount" of $34,000. Accordingly, under section
86(a)(2) the amount of the Social Security benefits to be
included in petitioner's gross income is equal to the lesser of
$6,512 (the sum of 85 percent of the excess of $3,008 ($37,008
less $34,000) or $2,557 plus the lesser of $4,500 which is one-
half of the difference between the "adjusted base amount"
($34,000) and the "base amount" ($25,000) or one-half of the
benefits received ($3,955)), or 85 percent of the Social Security
benefits ($7,909) or $6,723. Respondent included $6,511 in gross
income.2
2 The difference is due to rounding.
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Last modified: May 25, 2011