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supra note 6)), was the $3,342.12 retirement distribution from
Mobil Pension Trust. That amount plus one-half of petitioner’s
2001 Social Security benefits ($8,808) equals $12,150.12, which
is less than $25,000. Therefore, petitioner received zero
includable Social Security benefits in 2001. Because his 2001
adjusted gross income of $3,342.12 is less than the sum of his
standard deduction and personal exemption ($4,550 plus $2,900, or
$7,450), petitioner owes no tax for 2001. As a result,
petitioner is not liable for any tax deficiency for 2001.
2. 2002
For 2002, respondent alleges that petitioner is taxable on
the $3,342.12 retirement distribution from Mobil Pension Trust
(which was reported by petitioner on the 2002 Form 1040, line 7,
wages, salaries, tips, etc., rather than line 16b, pensions and
annuities), and on $18,040.80 of Social Security benefits
received in 2002. In 2002, as in 2001, respondent failed to
compute petitioner’s includable Social Security benefits under
section 86. In 2002, as in 2001, the sum of petitioner’s
adjusted gross income, other than Social Security benefits,
($3,342.12) plus one-half of his Social Security benefits
($9,020), a total of $12,362.12, is less than $25,000 so that
petitioner received zero includable Social Security benefits.
Because his 2002 adjusted gross income of $3,342.12 is less than
the sum of his standard deduction and personal exemption ($4,700
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