Victor E. Biyo and Amor O. Biyo - Page 3

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               Respondent determined a deficiency of $5,807 in petitioners’           
          2001 Federal income tax and a $1,161 section 6662(a) accuracy-              
          related penalty.  After concessions by respondent, the following            
          issues remain for consideration:  (1) Whether any portion of the            
          Social Security disability benefits received by Victor E. Biyo              
          during 2001 is includable in petitioners’ income for that year;             
          and (2) whether the interest income reported on petitioners’ 2001           
          joint Federal income tax return is understated.                             
          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 Seattle, Washington.  References to petitioner are to            
          Victor E. Biyo.                                                             
               Petitioners are, and were during all relevant periods,                 
          married to each other.  During the taxable year in issue,                   
          petitioner was unemployed, and Amor Biyo was self-employed as a             
          real estate salesperson.                                                    
               During 1998, petitioner made a claim for Social Security               
          disability benefits.  Ultimately, he was deemed eligible for and            
          awarded Social Security disability benefits in 2001.  During that           
          year he received Social Security disability benefits totaling               
          $43,494 (the benefits).  Although paid in a lump sum in 2001,               









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