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petitioner on her 1996 income tax return. Respondent disallowed
the earned income credit on the ground that petitioner did not
have any earned income in 1996.1 Accordingly, the issue for
decision is whether petitioner had earned income in 1996. We
hold that she did not.
FINDINGS OF FACT
Most of the facts have been stipulated, and they are so
found. Petitioner resided in Michigan at the time that her
petition was filed with the Court.
In 1996, petitioner received payments in the form and in the
amounts as follows:
Form of Payment Amount of Payment
Aid to Families with
Dependent Children
(AFDC) $3,998
Supplemental Securi-
ty Income (SSI) 74
Social Security Dis-
ability Benefits 5,640
Gifts 1,500
Total 11,212
Petitioner was not issued any Form W-2 (Wage and Tax
Statement) for the taxable year 1996. Other than the payments
1 Respondent did not determine, nor did respondent contend
at trial, that petitioner is not otherwise entitled to an earned
income credit.
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