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Topic
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Robbe, a cash basis single taxpayer, reported $50,000 of adjusted gross income last year and
claimed itemized deductions of $5,500, consisting solely of $5,500 of state income taxes paid last
year. Robbe’s itemized deduction amount, which exceeded the standard deduction available to
single taxpayers for last year by $1,150, was fully deductible and it was not subject to any
limitations or phase-outs. In the current year, Robbe received a $1,500 state tax refund relating to
the prior year.What is the proper treatment of the state tax refund?
a. Include $1,500 in income in the current year.
b. Amend the prior-year’s return and reduce the claimed itemized deductions for that year.
c. Include none of the refund in income in the current year.
d. Include $1,150 in income in the current year.
Explanation
Rule: IRC Section 111 provides that gross income does not include income attributable to the
recovery during the taxable year of any amount deducted in any prior taxable year to the extent
such amount did not reduce the amount of tax previously imposed (the tax benefit rule).
Choice “d” is correct. Under the tax benefit rule, an itemized deduction recovered in a subsequent
year is included in income in the year recovered. In this question, only $1,150 of the state income
taxes was actually deducted as an itemized deduction last year. The recovery is thus limited in the
amount actually deducted (and not to the entire amount of the state tax refund).
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Can anyone explain this to me? I thought as long as you itemized last year, your state tax refund received this year is taxable?
FAR - Passed
AUD - Passed
BEC - Passed
REG - 8/22/2013
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