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On their 1992 Federal income tax return, petitioners
reported total pension and annuity income in the amount of
$22,010, of which they included $1,496 in their gross income for
that year.
In the notice of deficiency, respondent determined that no
portion of petitioner’s pension for the 1992 taxable year was
excludable from gross income and increased petitioners’ 1992
taxable income in the amount of $20,514.1 Respondent also made
computational adjustments to petitioners’ Schedule A itemized
medical and dental expense deductions which increased
petitioners’ taxable income an additional $1,538.58 for 1992.
Respondent filed a motion for summary judgment with this
Court, together with supporting documents, on November 15, 1999.
By Order dated November 17, 1999, the Court calendared the motion
for hearing on February 14, 2000, and ordered petitioners to file
an objection to Respondent’s Motion for Summary Judgment on or
before January 7, 2000. Petitioners timely filed an objection to
Respondent’s Motion for Summary Judgment, together with
supporting documents. When the case was called for hearing on
1 This amount was calculated by the difference between
$22,010 and $1,496 which was reported as gross income in their
1992 tax return.
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