Clenzo and Louella Knox - Page 6

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          petitioners paid taxes on the deferred income.  The Court,                  
          therefore, sustains respondent.4                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                             Decision will be entered                 
                                        for respondent.                               























               4Petitioners received Social Security benefits during the              
          year 2000.  Adjustments were made in the notice of deficiency               
          with respect to the taxable amount of those benefits.  The                  
          adjustment to this item is computational based on our conclusion            
          with respect to the disputed issue.                                         





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