MEMORANDUM OPINION
DEAN, Special Trial Judge:
Respondent determined deficiencies of $2,632 and $2,260 in petitioners' 1996 and 1997 Federal income taxes, respectively. The issue for decision is whether Social Security benefits received by petitioner John M. Mikalonis (petitioner) in 1996 and 1997 include the worker's compensation payments he received from a private insurer in each year.
The facts have been fully stipulated and are so found. All section...
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