- 2 - Respondent determined a deficiency in petitioners’ Federal income tax for 1997 in the amount of $1,564. After concessions by the parties,2 the issues for decision are as follows: (1) Whether petitioners may exclude from gross income disability benefits received by petitioner D. Lloyd Thomas. We hold that petitioners may exclude such benefits. (2) Whether petitioners received interest on an overpayment of income tax for 1993. We hold that petitioners received such interest. Background Some of the facts have been stipulated, and they are so found. Petitioners resided in Copperas Cove, Texas, at the time that their petition was filed with the Court. At all relevant times, petitioners utilized the cash receipts and disbursements method of accounting in computing their taxable income. See sec. 446(c)(1). 2 Petitioners concede that in 1997 they were credited with interest on overpayments of income tax for 1992, 1994, and 1995 in the amounts of $49.86, $161.84, and $7.03, respectively, as determined by respondent in the notice of deficiency. Respondent concedes that the deficiency determined in the notice of deficiency ($1,564) is overstated because of a computational error and that the correct amount of the deficiency is $1,451. The parties agree that adjustments to petitioners’ IRA deduction and Schedule A deductions are computational matters, the resolution of which depends on our disposition of the two disputed issues identified above.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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