§18082

That same year, she also received a lump-sum distribution through the Social Security Administration (SSA) for disability benefits relating to the 2015, 2016, and 2017 tax years. Ms. Heston did not include the disability benefits as part of her modified adjusted gross income (MAGI)3 on her 2017 tax return. The Commissioner deter

18082 (2012)); see also Johnson v. Commissioner, 152 T.C. 121, 124 (2019). C. MAGI and Social Security Benefits Section 86(d)(1) defines “social security benefit[s]” as “any amount received by the taxpayer by reason of entitlement to--(A) a monthly benefit under title II of the Social Security Act, or (B) a tier 1 railroad retirement benefit.”

Treasury made these APTC payments on the basis ofpetitioners' projected household income and their expected eligibility for a tax credit under section 36B. The APTC payments, totaling $8,420 in 2014, reduced petitioners' monthly premium on each Blue Shield plan by at least $700. On October 15, 2015, petitioners timely filed for 2

The advance PTC payments are generally paid directly to the insurer. 42 U.S.C. sec. 18082. Sometimes circumstances change, and a taxpayer's actual annual income might turn out to be more or less than was estimated in making the eligibility determination for the advance PTC payments. In that event the advance PTC payments made o

I. Modified Adjusted Gross Income The parties' dispute concerns whether petitioner is entitled to any part ofthe PTC. Before we are able to decide the amount ofany credit, we must first decide whether petitioner is required to include in MAGI any ofthe Social Security benefits he received during 2014, including the nontaxable am

APTCs made on behalfofa taxpayer or members ofthe taxpayer's household, including dependent children, must be reported on the taxpayer's Form 1040. Ifthe amount ofthe APTCs exceeds the PTC to which the taxpayer is - 6 - [*6] entitled, the excess increases the tax owed by the taxpayer and reduces any refund otherwise payable to

The APTC is generally paid directly to the insurer. 42 U.S.C. sec. 18082. 7(...continued) period preceding the taxable year. Sec. 36B(d)(3); sec. 1.36B-1(h), Income Tax Regs. - 6 - [*6] Sometimes circumstances change, and a taxpayer's actual annual income might turn out to be more or less than was estimated in making the eligi

1.36B-2(a), Income Tax Regs.; see also McGuire v.

Advance payments ofthe premium assistance tax credit made on behalfofa taxpayer or members ofthe taxpayer's household, including a dependent child, must be reported on the taxpayer's Form 1040. Ifthe advance payments exceed - 5 - [*5] the premium assistance tax credit to which the taxpayer is entitled ultimately, the excess increases t