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Respondent determined a deficiency in petitioner’s Federal
income tax in the amount of $660 for taxable year 2000. The
issue for decision is whether a portion of the Social Security
benefits received by petitioner in 2000 is includable in her
gross income.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing her
petition, petitioner resided in Elkridge, Maryland.
During the year in issue, petitioner received Social
Security benefits totaling $8,756. Petitioner filed a Form 1040,
U.S. Individual Income Tax Return, for the 2000 taxable year.
She reflected her filing status as “single” and reported adjusted
gross income of $29,278. This amount did not, however, include
any of the $8,756 of Social Security benefits that petitioner
received during the 2000 taxable year.
Respondent contends that a portion of the Social Security
benefits petitioner received in 2000 is includable as gross
income under section 86. Petitioner contends otherwise, claiming
that taxing Social Security benefits is unfair and amounts to
double taxation.
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