William E. Conroy, Jay C. Dobbs, James W. Jenkins and Charles J. Tauter v. Commissioner of Internal Revenue

We concur in the judgment of the Tax Court that the proceeds received by these taxpayers from the Special Fund of the Baltimore City Police Department were includable in their gross income for federal income taxation purposes. In order for the taxpayers to prevail in their contention that these proceeds were excludable from gross income under the provisions of § 104(a) (3) read in conjunction with § 105(e), it would be necessary for us to reach the following conclusions:(a) that the Special Fund here involved qualified as an accident and health insurance plan;(b) that the payments received…