A. Joyce Payne v. United States
Court of Appeals for the Second Circuit
1Opinion of the Court
TIMBERS, Circuit Judge:
In this case of first impression at the appellate level, appellant A. Joyce Payne appeals from a summary judgment in favor of the United States and against Payne, entered in the District of Vermont, Albert W. Coffrin, Senior District Judge, 778 F.Supp. 804 (D.Vt.1991). The court held, as a matter of law, that the Panama Canal Commission (“PCC”) was an agency of the United States Government, and therefore, wages paid to employees of that agency, including appellant’s husband, are not ex-cludable from taxable income under 26 U.S.C. § 911 (1988), which exempts from…
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