Legal Opinion

Rembold v. Commissioner

United States Tax Court

Decided January 11, 1966No. Docket No. 3760-63Unpublished

Petitioner, a former member of the Baltimore City Police Department, was retired on account of physical disability in 1947 and received payments through the taxable years involved from a Special Fund made up of certain fines and rewards, contributions by member employees, and appropriations by the city.

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Petitioner, a former member of the Baltimore City Police Department, was retired on account of physical disability in 1947 and received payments through the taxable years involved from a Special Fund made up of certain fines and rewards, contributions by member employees, and appropriations by the city. Held, the payments are not excludable as "accident or health insurance" or as "amounts received under workmen's compensation acts" within the meaning of secs. 104 and 105 of the Internal Revenue Code of 1954.

1Opinion of the Court

Frederick W. Rembold and Helena F. Rembold v. Commissioner.

Rembold v. Commissioner

Docket No. 3760-63.

United States Tax Court

T.C. Memo 1966-7; 1966 Tax Ct. Memo LEXIS 275; 25 T.C.M. (CCH) 19; T.C.M. (RIA) 66007;

January 11, 1966

Petitioner, a former member of the Baltimore City Police Department, was retired on account of physical disability in 1947 and received payments through the taxable years involved from a Special Fund made up of certain fines and rewards, contributions by member employees, and appropriations by the city. Held, the payments are not excludable as "accident or health…

2Cases cited8 opinions

  1. Simms v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1952
  2. Neill v. CommissionerUnited States Tax Court · 1951
  3. Simms v. CommissionerUnited States Tax Court · 1951
  4. Conroy v. CommissionerUnited States Tax Court · 1964
  5. Brown v. CommissionerUnited States Tax Court · 1955

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