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in income under certain circumstances not applicable to this
case. Sec. 86(a)(2).
With the inclusion of $7,340 in gambling winnings,
petitioner’s adjusted gross income is $21,459. The sum of
petitioner’s adjusted gross income of $21,459 and one-half of
petitioner’s Social Security benefits of $5,544 exceeds the
$25,000 base amount threshold by $2,003. Since the amount of
Social Security benefits includable in income is equal to the
lesser of (1) one-half of the Social Security benefits received
of $5,544 or (2) one-half of the amount by which petitioner’s
modified adjusted gross income plus one-half of Social Security
benefits received during the year exceeded the $25,000 base
amount, or $1,002 (one-half of $2,003, rounded to the nearest
whole dollar), we sustain respondent’s determination that
petitioner must include $1,002 of Social Security benefits in
gross income.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011