Pearson v. Commissioner
United States Tax Court
Held, since petitioner was not permanently or totally disabled when he retired from the U.S. Air Force in 1970 or as of Jan. 1, 1976, he is not entitled to an exclusion for disability or sick pay for 1977 under the provisions of sec. 105(d), I.R.C. 1954, as applicable to years beginning after Dec. 31, 1976.
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the calendar year 1977 in the amount of $1,623. The only issue for decision is whether petitioners are entitled to a disability income tax exclusion for the calendar year 1977 under the provisions of section 105(d), I.R.C. 1954,1 as applicable to years beginning after December 31,1976.
All of the facts have been stipulated and are found accordingly-
Petitioners, husband and wife, who resided in Houston, Tex., at the time of the filing of the petition in this case, filed a joint Federal income tax…
2Cases cited1 opinion
- Crooks v. HarrelsonSupreme Court of the United States · 1930
3Cited by13 opinions
- Haar v. CommissionerUnited States Tax Court · 1982
- Bagnell v. CommissionerUnited States Tax Court · 1993
- Beard v. CommissionerUnited States Tax Court · 1984
- Black v. CommissionerUnited States Tax Court · 1981
- Boyd v. CommissionerUnited States Tax Court · 1983
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