- 3 -
disease". To compound petitioner's medical problems, petitioner
was injured when she fell while on the job. Petitioner has
severe arthritis, has had one knee replaced, and, as of the date
of trial, was scheduled for surgery to replace her other knee.
These maladies have left petitioner completely and permanently
disabled. In October 1990, at the age of 54, petitioner retired
from the Postal Service due to her disability. Petitioner
subsequently began receiving a FERS disability retirement annuity
(disability annuity). Petitioner received disability annuity
payments during 1992 and 1993 in the amounts of $10,954 and
$11,182, respectively.
Petitioner was told by the U.S. Office of Personnel
Management (OPM) that her disability annuity was not subject to
Federal income tax. No Federal income tax was withheld from the
payments. As a result of the advice from OPM petitioner did not
file Federal income tax returns for the taxable years 1992, 1993,
or 1994.
Respondent issued a notice of deficiency for the taxable
years 1992 and 1993. In the notice of deficiency respondent
determined that petitioner failed to report the disability
annuity payments, as well as interest and dividend income in the
amounts of $258 and $149, respectively, as gross income for the
taxable years 1992 and 1993. As of the date of trial, no notice
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011