Jay Sewards and Frances Sewards v. Commissioner

OPINION

Foley, Judge:

The issues for decision, relating to petitioners’ 2006 joint Federal income tax return, are whether petitioners may exclude certain retirement payments from income and whether petitioners are liable for a section 6662(a) 1 accuracy-related penalty. The parties submitted this case fully stipulated pursuant to Rule 122.

Background,

On November 29, 2000, after many years of employment with the Los Angeles County Sheriffs Department (Sheriffs Department), and because of service-connected injuries, Jay Sewards was placed on involuntary medical disability leave. While on…