Legal Opinion

Woodford v. Commissioner

United States Tax Court

Decided March 12, 1979No. Docket No. 8588-76Published

Petitioner, a former United States Civil Service employee, was retired on disability as of Nov. 24, 1974, prior to his reaching the mandatory retirement age.

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Petitioner, a former United States Civil Service employee, was retired on disability as of Nov. 24, 1974, prior to his reaching the mandatory retirement age. During 1975, he received disability retirement payments in the amount of $ 10,879 and excluded $ 5,200 thereof from his gross income as sick pay pursuant to sec. 105(d), I.R.C. 1954. Held, petitioner is not entitled in 1975 under sec. 72(d), I.R.C. 1954, to exclude from his gross income the $ 5,679 in excess of the sick pay exclusion as a recovery of his contributions to the retirement system. Held, further, the $ 5,679, in excess of the…

1Opinion of the Court

William I. Woodford and Madge L. Woodford, Petitioners v. Commissioner of Internal Revenue, Respondent

Woodford v. Commissioner

Docket No. 8588-76

United States Tax Court

71 T.C. 991; 1979 U.S. Tax Ct. LEXIS 159;

March 12, 1979, Filed

Decision will be entered for the respondent.

Petitioner, a former United States Civil Service employee, was retired on disability as of Nov. 24, 1974, prior to his reaching the mandatory retirement age. During 1975, he received disability retirement payments in the amount of $ 10,879 and excluded $ 5,200 thereof from his gross income as sick pay pursuant to sec.…

2Cases cited3 opinions

  1. De Paolis v. CommissionerUnited States Tax Court · 1977
  2. Brownholtz v. CommissionerUnited States Tax Court · 1978
  3. Woodford v. CommissionerUnited States Tax Court · 1979

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