Will L. and Rachel A. Thomas - Page 1

                                 T.C. Memo. 2001-120                                  

                               UNITED STATES TAX COURT                                

                    WILL L. AND RACHEL A. THOMAS, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17397-99.                     Filed May 21, 2001.           

               Rachel A. Thomas, pro se.                                              
               Linda M. Davis, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge: Respondent determined a               
          deficiency of $1,432 in petitioners' 1997 Federal income tax.1              
               The sole issue for decision is whether Social Security                 
          disability benefits received by petitioner Will L. Thomas                   
          (petitioner) during 1997 are includable in gross income under               

               1    Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the year at issue.               

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