- 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 judgment. 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 NextLast modified: November 10, 2007