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entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined an $11,599 deficiency in petitioners’
2000 Federal income tax and a $483 section 6651(a)(1) addition to
tax for that year. The issues for decision are: (1) Whether
Social Security benefits received on account of Nancy Rae
Patten’s physical disability are includable in petitioners’
income; and (2) whether petitioners’ failure to file a timely
2000 Federal income tax return is due to reasonable cause.
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed in this case, petitioners
resided in Lake Stevens, Washington. Petitioners are, and were
during all relevant periods, married to each other. They filed a
joint Federal income tax return for the year in issue. Nancy R.
Patten (petitioner) is afflicted with multiple sclerosis and has
not been employed since 1994.
In 1995, petitioner filed for and was denied Social Security
disability benefits. She reapplied for disability benefits in
1998 and was again denied. She successfully appealed the
denials, and in 2000 she was awarded and received Social Security
disability benefits of $50,405. Although received entirely in
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