Juanita Doby - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax of $2,739 for the taxable year 2000.                             
               After concessions,1 the issues for decision are:  (1)                  
          Whether petitioner is liable for tax on payments in the amount of           
          $3,146.04 received from The Equitable Benefits Payment Services             
          pursuant to her deceased husband’s PEPCO pension plan; and (2)              
          whether petitioner is liable for tax on individual retirement               
          account (IRA) distributions received during taxable year 2000               
          totaling $11,400.  The amount of petitioner’s Social Security               
          benefits received during 2000 that must be included in her gross            
          income is a computational matter and will be resolved by the                
          parties after taking into account the concessions and our                   
          decision on the other issues in this case.                                  
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               




          1At trial and in the stipulation of facts, petitioner                       
          conceded:  (1) She received $12 of interest income from                     
          Educational Systems Federal Credit Union during the 2000 tax                
          year; (2) she received $10 interest income from Household Bank              
          during the 2000 tax year; and (3) she was liable for tax on                 
          discharge of indebtedness income in the amount of $1,137, which             
          was the result of Worldwide Financial Services’ canceling a debt            
          owed by petitioner during taxable year 2000.  Also at trial,                
          respondent conceded that petitioner was entitled to claim a child           
          care credit and a child tax credit.                                         





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