Carolyn J. Guilzon, Individually and as of the Estate of Edward J. Guilzon, Deceased v. Commissioner of Internal Revenue

JOHNSON, Circuit Judge:

This case calls on the Court to construe statutory provisions affecting the taxation of lump-sum benefits provided to Civil Service retirees. The United States Tax Court held that a portion of lump-sum payments are taxable. We affirm.

I. Facts and Procedural History

Edward Guilzon worked for the United States Army Corps of Engineers as a civil servant for more than thirty years. Throughout that thirty-year period, Mr. Guilzon contributed a percentage of his gross salary to the Civil Service Retirement System (CSRS). He paid taxes on all of those contributions, which, upon…