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Respondent determined a deficiency of $2,835 in petitioner’s
Federal income tax for the year 2002.
The sole issue for decision is whether Social Security
benefits received by petitioner during 2002 are includable in
gross income under section 86(a).2
Some of the facts were stipulated. Those facts and the
accompanying exhibits are so found and are incorporated herein by
reference. Petitioner’s legal residence at the time the petition
was filed was Shreveport, Louisiana. Petitioner was married and
lived with his wife at Shreveport, Louisiana.
Petitioner has a degree in architectural engineering and,
during the year at issue, was employed as construction
superintendent on a 2-year project at Reno, Nevada. For the
duration of his employer’s construction contract, which included
the year 2002, petitioner rented an apartment at Reno, Nevada.
His spouse did not move to Reno but continued occupying their
residence at Shreveport, Louisiana. At trial, petitioner
acknowledged that, from time to time, he visited his spouse at
their Shreveport home during the 2-year period he was at Reno.
He also acknowledged that he and his spouse were not separated
2In the notice of deficiency, respondent determined that
petitioner earned interest income of $26 during the year at
issue. Petitioner did not address this determination at trial;
consequently, it is considered to be conceded by petitioner.
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