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determination that petitioners include a portion of the Social
Security disability benefits in their 2001 gross income.4
Finally, respondent determined that petitioners failed to
report $87 of interest income. The interest income reported on
petitioners’ 2001 return is understated by $87. Although
petitioners have not expressly conceded the point, nothing in the
record suggests that respondent’s adjustment increasing
petitioners’ income by that amount is in any way erroneous.
Accordingly, we sustain respondent’s determination with respect
to petitioners’ 2001 underreported interest income.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
4 According to the notice of deficiency, $30,585 of the
benefits must be included in petitioners’ 2001 income. We are
unable to duplicate the calculation that results in that amount,
as our calculation results in a larger number. The manner in
which respondent treated the $4,000 reimbursement for attorney’s
fees, which is unclear from the record, no doubt has something to
do with the discrepancy.
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Last modified: May 25, 2011