Robert E. and Carol J. Cawvey - Page 8

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          gross income under section 86.  Accordingly, we uphold                      
          respondent’s determination that petitioners’ gross income for the           
          taxable year 2001 is increased by $3,759 as a result of                     
          adjustments for taxable Social Security benefits under section              
          86.                                                                         
               Respondent’s computational adjustments to petitioner’s                 
          claimed medical expenses will be decided by our holding on the              
          issue.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                             Decision will be entered                 
                                        for respondent.                               

























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