Hines v. Commissioner
United States Tax Court
Petitioner, a pilot for a commercial airline, suffered a heart attack from which he eventually made a full recovery. Because of a regulation of the Federal Aviation Administration (FAA), however, petitioner was permanently disqualified from holding the FAA medical certificate necessary to retain his pilot's license. As a result, petitioner was eligible for benefits under the commercial airline's Loss of License Plan for Pilots.
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Petitioner, a pilot for a commercial airline, suffered a heart attack from which he eventually made a full recovery. Because of a regulation of the Federal Aviation Administration (FAA), however, petitioner was permanently disqualified from holding the FAA medical certificate necessary to retain his pilot's license. As a result, petitioner was eligible for benefits under the commercial airline's Loss of License Plan for Pilots. Held, petitioners were not entitled under sec. 105(c), I.R.C. 1954, to exclude payments received under the plan from their gross income because (1) the damage to…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency of $10,891.63 in petitioners’ income tax for 1975. Due to a concession by respondent, the only issue for decision is whether certain payments received by petitioner Oscar Hines may be excluded from petitioners’ gross income pursuant to section 105(c).1
This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and joint exhibits are incorporated herein by this reference. The pertinent facts are summarized below.
Oscar J. (hereinafter petitioner) and Virginia A. Hines…
2Cases cited1 opinion
- Laverty v. CommissionerUnited States Tax Court · 1973
3Cited by32 opinions
- Randall L. Beisler and Judith K. Beisler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Frank S. Watts and Barbara M. Watts v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- Stewart and Lillian Caplin v. United StatesCourt of Appeals for the Second Circuit · 1983
- Gordon v. CommissionerUnited States Tax Court · 1987
- Kenneth S. Rosen Lou Hill Davidson, (Johnnye) v. United StatesCourt of Appeals for the Fourth Circuit · 1987
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