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Respondent determined deficiencies in petitioner's Federal
income taxes of $2,526 for 1999 and $3,819 for 2000. The issues
for decision are whether petitioner, for both years, properly
reported pension income and is entitled to claim trade or
business expense deductions. Respondent's adjustments to
petitioner's itemized deductions and the taxable amount of his
Social Security benefits are computational and will be determined
by the Court's resolution of the income and expense issues.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Sacramento,
California.
Background
There is no disagreement among the parties as to the facts
in this case, which are almost fully stipulated. Before his
retirement in 1990, petitioner was self-employed as an
independent insurance agent for the New York Life Insurance
Company (company). After a surgery, petitioner retired on
disability due to heart-related health problems. Upon his
retirement, the company transferred his clients to another
insurance agent and began paying pension distributions to
petitioner. There is no indication that there was any
understanding that he would return to his position as an agent
for the company.
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