Tuka v. Comm'r
United States Tax Court
P excluded from gross income certain disability benefits that he received under a pilot disability plan funded by his employer, U.S. Airways, Inc. P alleges that in prior collective bargaining negotiations, the Airline Pilots Association and U.S. Airways pilots made wage concessions in exchange for the pilot disability plan.
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P excluded from gross income certain disability benefits that he received under a pilot disability plan funded by his employer, U.S. Airways, Inc. P alleges that in prior collective bargaining negotiations, the Airline Pilots Association and U.S. Airways pilots made wage concessions in exchange for the pilot disability plan. P argues that, in reality, the concessions he and the other pilots made represent the contributions to the pilot disability plan for purposes of sec. 104(a)(3), I.R.C. Held: P's employer, U.S. Airways, funded the pilot disability plan for purposes of sec. 104(a)(3),…
1Opinion of the Court
Ruwe, Judge:
Respondent determined a deficiency of $19,565 in petitioner’s Federal income tax for 1999 and an accuracy-related penalty under section 6662(a)1 of $3,913. Respondent concedes the accuracy-related penalty, and the issue for decision is whether certain disability benefits that petitioner received in 1999 were properly excluded from gross income under section 104(a)(3).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of filing the petition herein,…
2Cases cited1 opinion
- Trappey v. CommissionerUnited States Tax Court · 1960
3Cited by6 opinions
- Connors v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2008
- Connors v. Comm'rUnited States Tax Court · 2006
- Cotler v. Comm'rUnited States Tax Court · 2007
- Jon K. Palsgaard & Kimberly A. Kelly v. CommissionerUnited States Tax Court · 2018
- Thomas D. Tuka v. CommissionerUnited States Tax Court · 2003
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