Ivan and Karenza A. Mirosevic - Page 4

          of pension payments.  The $117,164 reported by petitioners for              
          2000 was received in 1999.                                                  
               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                    
                                                  Decision will be entered            
                                             under Rule 155.                          

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