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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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Last modified: May 25, 2011