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effect for the taxable year in issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency in petitioners' 1992
Federal income tax in the amount of $1,320. After concessions,
the issue for decision is whether petitioner George L. Willis'
1992 Social Security benefits include the worker's compensation
payments he received during that year.
The deficiency resulted from respondent's determination that
petitioners failed to include $8,833 of petitioner George L.
Willis' 1992 Social Security benefits in taxable income.
Respondent conceded that the unreported income attributable to
the taxable portion of petitioner George L. Willis' Social
Security benefits is a lesser amount than the $8,833 asserted in
the notice of deficiency, based on the limitation provisions of
section 86(e), and that such lesser amount is $7,378.
Petitioners conceded that if the worker's compensation that
petitioner George L. Willis received in 1992 is taxable as Social
Security benefits, petitioners are liable for tax on unreported
income in the amount of $7,378.
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
reference. Petitioners resided in Union City, California, when
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