Ivan and Karenza A. Mirosevic - Page 3

          Tax Court Rules of Practice and Procedure, and dollar amounts are           
          rounded to the nearest dollar.                                              
               We decide this case without trial.  See Rule 122.                      
          Petitioners petitioned the Court to redetermine a $19,728                   
          deficiency in their 2000 Federal income tax and a $4,608                    
          accuracy-related penalty under section 6662(a).  Following                  
          concessions by both parties, the sole issue left to decide is               
          whether petitioners’ 2000 taxable income includes $88,885 of                
          pension income not otherwise included in that taxable income.  We           
          hold it does.                                                               
               The facts in this background section are obtained from the             
          parties’ stipulation of facts and the exhibits submitted                    
          therewith.  Petitioners are cash method taxpayers who resided in            
          Croatia when their petition was filed with this Court.                      
               Petitioners filed a joint 2000 Federal income tax return on            
          which they reported the following items of income realized by               
          them during 2000:                                                           
               Wages                                $5,209                            
               Taxable interest                        126                            
               Taxable pension                      11,716                            
          Petitioners reported as to the taxable pension income that                  
          petitioner Ivan Mirosevic (Mirosevic) had received $117,164 of              
          pension payments during that year but that only $11,716 of those            
          payments was taxable.  During 2000, Mirosevic received $100,601             

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