Tony G. and Roberta A. Montgomery - Page 3

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               Respondent determined a deficiency of $1,586 in petitioners’           
          Federal income tax for the year 2001.                                       
               The sole issue for decision is whether Social Security                 
          benefits received by Tony G. Montgomery (petitioner) during 2001            
          are includable in gross income under section 86(a).                         
               Some of the facts were stipulated.  Those facts and the                
          accompanying exhibits are so found and are incorporated herein by           
          reference.  Petitioners’ legal residence at the time the petition           
          was filed was Marion, Illinois.                                             
               Petitioner was a career employee of The Kroger Co. (Kroger),           
          a nationwide super market chain, having worked for Kroger for 28            
          years.  He was employed in a managerial capacity overseeing                 
          approximately 80 Kroger stores in southern Indiana and southern             
          Illinois.  His duties required visiting each store to make sure             
          that the merchandising policies of the company were being                   
          followed.  In effect, he served as a liaison between the                    
          individual stores and the company headquarters.                             
               Petitioner was seriously injured during the course of his              
          employment sometime during 1990.  While he was at a store at                
          Mercury, Illinois, in connection with a remodeling of the store,            
          a customer accidentally rammed him with a shopping cart.  The               
          accident, as it turned out, caused petitioner to suffer serious             
          spinal injuries.  Although petitioner initially was not disabled,           
          and he continued working, he did so with pain, which, over                  





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