Larry G. and Helen M. Horst - Page 3




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          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.  At               






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