-3-
of pension payments. The $117,164 reported by petitioners for
2000 was received in 1999.
Discussion
Respondent determined that petitioners failed to report
$88,885 of pension income for 2000; i.e., the difference between
the reported amount of $11,716 and the $100,601 received by
Mirosevic during 2000. Petitioners concede that this
determination is correct, and they make no argument that they are
not liable for Federal income taxes payable on the $88,885. In
that a taxpayer’s gross income specifically includes income from
a pension, see sec. 61(a)(11), and that petitioners have not made
any claim that Mirosevic’s receipt of the $88,885 is otherwise
excepted from this rule, we sustain respondent’s determination as
to this issue in full. In order to reflect respondent’s
concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011