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the State disability retirement benefits, petitioner continued to
receive worker’s compensation benefits. In or around 1998,
petitioner’s worker’s compensation benefits ended.
In September 1995, petitioner applied for Social Security
disability insurance (SSDI) benefits, which were awarded in
November 1998. The SSDI award included amounts attributable to
earlier years. Petitioner’s SSDI benefits were offset, dollar
for dollar, by the amount of worker’s compensation benefits
petitioner received. In addition to the SSDI benefits,
petitioner continued to receive disability retirement benefits
from the State of Florida.
In 2000, petitioner received SSDI benefits of $33,867.
Portions of the amount received in 2000 included unpaid SSDI
benefits for the taxable years 1996, 1997, and 1998.
Petitioners timely filed their 2000 Federal income tax
return. Taking into account wages, interest, and pension
distributions, they reported adjusted gross income of $36,101.
Petitioners did not include any portion of the SSDI benefits
received by petitioner in the income reported on their 2000
return.
In the notice of deficiency, respondent determined that a
portion of the SSDI benefits ($13,679) received by petitioner
during 2000 is includable in petitioners’ income for that year.
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