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items included in petitioner’s income by respondent (income
inclusions or inclusions), after concessions,5 are as follows:
(1) “wages/misc. income” of $48,000 for 1998 and $14,400 for
1999; (2) retirement income of $1,114.04 for 1998 and $3,342.12
for each of the other 3 years in issue (1999, 2001, and 2002);
(3) interest income of $80.22 for 1998; and (4) Social Security
income of $17,5786 for 2001 and $18,040.80 for 2002.
4(...continued)
respondent describes as frivolous the positions taken and
arguments contained in those Forms 1040 and in the attachments
thereto.
5 Respondent proposed an increase in petitioner’s dividend
income for all 4 years in issue, but he has conceded those
adjustments because petitioner’s ex-wife was awarded the stock to
which those dividends related as part of a divorce decree. For
the same reason, respondent also has conceded a 1999 proposed
capital gain increase relating to gain from the sale of that
stock. Respondent has conceded an adjustment to petitioner’s
income for 2001 on account of discharge of indebtedness since no
discharge of the indebtedness occurred by the year’s end.
6 There is no explanation in the record of the apparent
discrepancy between the 2001 Form SSA-1099-SM attached to the
2001 Form 1040, which lists $17,616 of Social Security benefits
paid to petitioner (or for his benefit) for 2001, and the
Certification of Extract from Records issued by the Social
Security Administration, which lists $17,578 in total benefits
paid to petitioner (or for his benefit) for that year.
Respondent included the latter amount in petitioner’s income for
2001.
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