- 16 - B. 2001 and 2002 1. 2001 As will become apparent, it is important to keep in mind that respondent concedes two of the four proposed income inclusions for 2001: (1) cancellation of indebtedness income in the sum of $169,302, because the debt had not been discharged by the creditor, and (2) $57 of dividend income relating to stock that belonged to petitioner’s ex-wife. See supra note 5. Respondent’s remaining proposed inclusions in petitioner’s income for 2001 are (1) the retirement distribution of $3,342.12 from Mobil Pension Trust (which was reported by petitioner on the 2001 Form 1040) and (2) Social Security benefits of $17,578. In arguing that petitioner “realized taxable income in 2001 in the amount of $17,578” from Social Security benefits, respondent has apparently overlooked the impact of his concessions for 2001 upon the computation of includable Social Security benefits under section 86. Pursuant to section 86(a)(1)(B), (b), and (c)(1)(A), petitioner is taxable on no more than the excess of the sum of his modified adjusted gross income (not including his Social Security benefits) plus one-half of his 2001 Social Security benefits over $25,000 (petitioner’s “base amount” under section 86(c)(1)(A)). Petitioner and respondent agree that his only item of gross income, other than his Social Security benefits (assumed, for this purpose, to be $17,616 (seePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: November 10, 2007