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aggregate amount of $701 as reflected on Forms 1099 from
Southwest Trust Bank ($457) and Bank of Pensacola ($244).
Accordingly, we find petitioners have failed to meet their burden
of proving that respondent’s determination regarding the
foregoing was erroneous, and we sustain it. See Rule 142(a);
Welch v. Helvering, 290 U.S. 111 (1933).6
Issue 2. Social Security Payments
Respondent determined that during 1996 petitioners received
$8,496 in Social Security benefit payments and failed to include
85 percent of such payments ($7,222) in their gross income as
required by section 86. Section 86 requires the inclusion of a
portion of Social Security benefits in gross income when the sum
of the benefit recipient’s “modified” adjusted gross income plus
one-half of his or her Social Security benefits exceeds certain
threshold amounts. When, in the case of a joint return, this sum
exceeds $32,000, the lesser of such excess or 50 percent of the
Social Security benefits must be included in income. Sec.
86(a)(1), (c)(1)(B). When modified adjusted gross income exceeds
$44,000 in the case of a joint return, up to 85 percent of the
Social Security benefits received during the year must be
included in gross income. Sec. 86(a)(2), (c)(2)(B). Under
section 86, modified adjusted gross income in general equals
adjusted gross income plus tax-exempt interest income received
6 See supra note 4.
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