- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011