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belongings had been moved from California, petitioner’s wife
purchased new furniture for use there. She remained in
California, caring for her daughter and granddaughter and working
at San Francisco General Hospital. After petitioner completed
his medical treatment, he moved back to California. He began
driving from Washington, D.C., on or about December 26, 1997,
stopped in Decatur, Georgia, to spend the New Year holiday with
his sister, and arrived in San Francisco on or about January 4,
1998.
Petitioner received Social Security disability benefits of
$26,364 in 1997. These benefits were attributable to 1996 and
1997. Of the total amount, $20,011 was paid to petitioner
directly, $44 was paid on behalf of petitioner for Medicare
premiums, and the remaining $6,309 was paid to petitioner’s
lawyer.
Petitioner filed a Federal income tax return for 1997 as a
married person filing a separate return. He reported $20,490 in
adjusted gross income,2 but has since conceded that his 1997
2The notice of deficiency reflects taxable income as shown
on petitioner’s return to be $16,389. Petitioner’s return shows
$14,389. This $2,000 discrepancy was apparently an attempt by
respondent to correct a mathematical error in petitioner’s
computation of adjusted gross income. The following computation
appears on petitioner’s return:
(continued...)
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