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Why would it be hard if a single person got $32K of Social Security plus a $9K pension from the PBGC ($25K provisional income) plus another $XX,000 from a Roth IRA?

Because the $25k limit is not adjusted for inflation, but SS is. So in your example, if there is a 1.5% inflation adjustment ($480), that $480 will be taxed, and the taxpayer will no longer be one of those who 'pay no income taxes.' The taxable amount will continue to grow with every SS inflation adjustment.

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