Wallace v. Comm'r
United States Tax Court
P participated in a compensated work therapy program administered by the U.S. Department of Veterans Affairs (VA) and, on account thereof, received a distribution of $ 16,393 from the VA Special Therapeutic and Rehabilitation Activities Fund. R increased P's gross income by that amount on the ground that the distribution is a payment for services.
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P participated in a compensated work therapy program administered by the U.S. Department of Veterans Affairs (VA) and, on account thereof, received a distribution of $ 16,393 from the VA Special Therapeutic and Rehabilitation Activities Fund. R increased P's gross income by that amount on the ground that the distribution is a payment for services. P claims that the distribution is a tax-exempt veterans' benefit pursuant to I.R.C. sec. 139(a)(3) and 38 U.S.C. sec. 5301 (2000). Held: The distribution is a tax-exempt veterans' benefit.
1Opinion of the Court
OPINION
HALPERN, Judge:
Respondent determined a deficiency of $2,460 in petitioner’s 2000 Federal income tax. The sole issue for decision is whether $16,393 received by petitioner during 2000 in connection with his participation in a work therapy program administered by the U.S. Department of Veterans Affairs (VA) is includable in his gross income for 2000. We hold that it is not.
Unless otherwise stated, all section references are to the Internal Revenue Code in effect for 2000.
Background
Introduction
This case was submitted for decision without trial pursuant to Rule 122, Tax Court Rules of…
2Cases cited23 opinions
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- Jarecki v. G. D. Searle & Co.Supreme Court of the United States · 1961
- Rose v. RoseSupreme Court of the United States · 1987
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