Wright v. Comm'r
United States Tax Court
Ps excluded a portion of H's disability benefits from gross income for the 1999 and 2000 taxable years. R determined that Ps were required to include in gross income an additional portion of H's benefits.
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Ps excluded a portion of H's disability benefits from gross income for the 1999 and 2000 taxable years. R determined that Ps were required to include in gross income an additional portion of H's benefits. Held: Ps are not entitled under sec. 105, 104(a)(3), or 72,I.R.C., to exclude from gross income disability retirement benefits in an amount greater than permitted by R. Held, further, R is not precluded from making adjustments to Ps' gross income by reason of R's decision not to adjust prior years' income.
1Opinion of the Court
THOMAS G. WRIGHT AND ESTATE OF ROSEMARY K. WRIGHT, DECEASED, THOMAS G. WRIGHT, PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wright v. Comm'r
No. 9988-03
United States Tax Court
T.C. Memo 2005-5; 2005 Tax Ct. Memo LEXIS 5; 89 T.C.M. (CCH) 662;
January 13, 2005, Filed
Judgment entered for respondent.
Ps excluded a portion of H's disability benefits from gross income for the 1999 and 2000 taxable years. R determined that Ps were required to include in gross income an additional portion of H's benefits.
Held: Ps are not entitled under sec. 105, 104(a)(3), or…
2Cases cited34 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Office of Personnel Management v. RichmondSupreme Court of the United States · 1990
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