Ann Powers, F/K/A Melanie Ann Studinger - Page 2




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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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