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adjusted base amount of $44,000, in the case of a joint return.
See sec. 86(a)(2), (c)(2)(B).
The increased percentage is not applicable because
petitioner did not exceed the threshold for the adjusted base
amount. One-half of the excess described in section 86(b)(1) was
$5,401.45 (($42,802.89 - $32,000)/2), which is less than one-half
of the total Social Security benefits received.
Accordingly, the Court sustains respondent’s determination
that $5,401 of the Social Security benefits received by
petitioner and Mrs. Jacobs in 2003 is includable in their gross
income for that year.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011