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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions by the parties,1 the sole issue for
decision is whether payments petitioner received for nursing and
attendant care services she provided to her permanently disabled
husband must be included in petitioner’s gross income for the
1994, 1995, and 1996 taxable years.
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
1 Petitioner concedes that she received the following
amounts which are includable in gross income for 1994: (1)
Gambling winnings of $3,700; (2) patronage dividends of $1,026;
and (3) pensions/annuities of $1,266. Petitioner also concedes
that she received the following amounts which are includable in
gross income for 1995: (1) Patronage dividends of $320; and (2)
pensions/annuities of $504.
Respondent makes the following concessions: (1) That only
$1,266 of the $2,532 petitioner received from the Social Security
Administration is includable in gross income for 1994; (2) for
the 1995 taxable year, that petitioner is not required to include
in gross income $300 of the payments reported as paid to
petitioner by Healthcare Corp. and that only $504 of the $1,968
petitioner received from the Social Security Administration is
includable in gross income; (3) that petitioner and Mr. Baldwin
were married during the years in issue and are therefore entitled
to married, filing jointly status for the 1994, 1995, and 1996
taxable years; (4) that petitioner’s son, Floyd, was a dependent
of petitioner and Mr. Baldwin during the 1994 and 1995 taxable
years and that petitioner’s children, Emma and Sam, were
dependents of petitioner and Mr. Baldwin during the 1994, 1995,
and 1996 taxable years; and (5) that petitioner is not liable for
the additions to tax pursuant to secs. 6651(a)(1), (2), and
6654(a).
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Last modified: May 25, 2011