Theodore Major Green and Jacqueline Green - Page 4

                                        - 4 -                                         
          judgment in taxable income, and the record does not establish               
          that petitioner had any tax basis in the uncollected judgment.              
               On their 1997 joint Federal income tax return filed with               
          respondent, petitioners reported as taxable $5,789 of the Social            
          Security benefits petitioner received in 1997, and petitioners              
          claimed a $11,068 casualty loss deduction relating to the above             
          $166,013 uncollected judgment.  Petitioners also attached to                
          their 1997 tax return a statement that they intended to deduct              
          the balance of the $154,946 uncollected judgment over the course            
          of the next 15 years –- $11,068 in each year -– as a loss                   
          carryforward under section 172.                                             
               For 2003, the year at issue herein, petitioners filed a                
          joint Federal income tax return, reported thereon $6,604 as the             
          taxable portion of the Social Security benefits petitioner                  
          received, and claimed the $11,068 loss carryforward mentioned               
          above relating to petitioner’s 1996 $166,013 uncollected                    
               After an audit of petitioners’ 2003 Federal income tax                 
          return, on December 5, 2005, respondent mailed to petitioners a             
          notice of deficiency reflecting a $437 tax deficiency for 2003              
          based on a recalculation of the portion of Social Security                  
          disability benefits petitioner received in 2003 that was taxable.           

Page:  Previous  1  2  3  4  5  6  7  8  9  Next 

Last modified: November 10, 2007