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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a $2,053 deficiency in petitioners’
2003 Federal income tax. The issues for decision are: (1)
Whether Social Security disability benefits received by
petitioner Marcia Goldfarb are taxable, and (2) whether
respondent is estopped from determining a deficiency against
petitioners with respect to the benefits.1
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time the petition was filed,
petitioners resided in Wesley Chapel, Florida. Unless otherwise
indicated, references to petitioner are to Marcia Goldfarb.
Petitioner formerly worked for the Montgomery County,
Maryland, police department. In 1998, petitioner retired due to
a work-related injury that left her disabled and began receiving
Social Security disability benefits. In 2003, petitioner
received $13,524 of disability benefits from the Social Security
Administration.
Petitioners filed a joint 2003 Federal income tax return
reporting $76,633 of adjusted gross income. This amount did not
1 Petitioners filed a Motion for Summary Judgment on Dec. 5,
2006. For the reasons discussed infra, we shall deny
petitioners’ motion.
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