Robert B. and Daisy A. Miley - Page 2




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               Section references are to the Internal Revenue Code in                 
          effect for 1997.  Rule references are to the Tax Court Rules of             
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners are married and resided in Glen Burnie,                    
          Maryland, when they filed their petition.                                   
               Petitioner worked for Hearth Home Doors, LLC (Hearth Home)             
          in January 1997.  He earned about $450 a week at that time.  On             
          his 16th day of work in 1997, petitioner was injured in an                  
          automobile accident.  His injuries caused him to miss several               
          months of work.  He never returned to work for Hearth Home.                 
          B.   Petitioner’s Disability Payments                                       
               Hearth Home was the plan holder for a disability insurance             
          policy issued by Guardian Life Insurance Co. of America                     
          (Guardian) that covered petitioner.  Guardian paid disability               
          payments to petitioner totaling $7,618 from January 17 to July              
          17, 1997, less amounts Guardian withheld for Social Security and            
          Medicare taxes.                                                             
          C.   Petitioners’ 1997 Return                                               
               In February 1998, Hearth Home issued to petitioner a Form W-           
          2, Wage and Tax Statement, which stated that he received $9,149             
          in wages in 1997.  Petitioners did not report any income from               






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