John M. and Norma A. Mikalonis - Page 1

                                       T.C. Memo. 2000-281                                             

                                     UNITED STATES TAX COURT                                           

                       JOHN M. AND NORMA A. MIKALONIS, Petitioners v.                                  
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket Nos. 1060-99, 11599-99.        Filed August 31, 2000.                         

                  Harry C. Citrino, Jr., for petitioners.                                              
                  Joellyn R. Cattell, for respondent.                                                  

                                        MEMORANDUM OPINION                                             
                  DEAN, Special Trial Judge:  Respondent determined                                    
            deficiencies of $2,632 and $2,260 in petitioners’ 1996 and 1997                            
            Federal income taxes, respectively.  The issue for decision is                             
            whether Social Security benefits received by petitioner John M.                            
            Mikalonis (petitioner) in 1996 and 1997 include the worker’s                               
            compensation payments he received from a private insurer in each                           

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