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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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