- 6 - Mikalonis v. Commissioner, T.C. Memo. 2000-281. According to petitioner, a portion of the lump-sum benefits received in 2000 was a “rebate for attorney’s fees.” To the extent that petitioner incurred attorney’s fees in securing the SSDI award, those fees might well have been deductible. See sec. 212(1). Nevertheless, there is insufficient evidence in the record to establish the amount of the fees, or the proper year for any such allowable deduction. Taking into account petitioners’ 2000 filing status, their 2000 modified adjusted gross income, and the SSDI benefits petitioner received that year, we find respondent’s determination as to the portion of petitioner’s SSDI benefits includable in petitioners’ 2000 gross income is sustained. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
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