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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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