- 3 - were allocated as follows: Date Tier I Tier II Total 1994 $10,710 $1,851 $12,561 1995 13,212 2,241 15,453 1996 13,560 2,259 15,819 Total $37,482 $6,351 $43,833 The RRB submitted Forms 1099-SSA and 1099-R to the Internal Revenue Service (IRS) reporting that RRB paid Tier I and Tier II benefits to petitioner in 1996 in the amounts of $37,482 and $6,351, respectively. CSX submitted a Form 1099-DIV to the IRS reporting that CSX paid $44 in dividends to petitioners in 1996, and Hagerstown Trust submitted a Form 1099-INT to the IRS reporting that Hagerstown Trust paid $21 in interest to petitioners in 1996. Petitioners did not report any of the above amounts on their 1996 Federal income tax return. In the notice of deficiency, respondent determined that petitioners were required to report (1) Tier I benefits in the amount of $1,572 and Tier II benefits of $6,351 received from the RRB, and (2) dividend and interest income, as noted above, received from CSX and Hagerstown Trust. Discussion I. RRB Payments The first issue for decision is whether petitioners were required to include in income $1,572 in Tier I benefits and $6,351 in Tier II benefits received from the RRB in 1996. AtPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011