Legal Opinion

Covert v. Commissioner

United States Tax Court

Decided November 21, 1990No. Docket No. 27767-88UnpublishedCited by 1 opinion

In 1985, P-husband received disability benefits from a disability plan established by his employer. The disability plan resulted from a negotiated labor contract. The disability benefits were not paid pursuant to a State worker's compensation statute and were paid without regard to whether the injury was work related. Ps also received a payment from the State Teacher's Retirement System of Ohio.

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In 1985, P-husband received disability benefits from a disability plan established by his employer. The disability plan resulted from a negotiated labor contract. The disability benefits were not paid pursuant to a State worker's compensation statute and were paid without regard to whether the injury was work related. Ps also received a payment from the State Teacher's Retirement System of Ohio. Held, the disability benefits are not excludable from gross income under I.R.C. sec. 104(a)(1). Held further, the amount received from the State Teacher's Retirement System of Ohio is not excludable…

1Opinion of the Court

JAMES E. AND CLARA J. COVERT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Covert v. Commissioner

Docket No. 27767-88.

United States Tax Court

T.C. Memo 1990-598; 1990 Tax Ct. Memo LEXIS 663; 60 T.C.M. (CCH) 1302; T.C.M. (RIA) 90598; 13 Employee Benefits Cas. (BNA) 1039;

November 21, 1990, Filed

Decision will be entered for the respondent.

In 1985, P-husband received disability benefits from a disability plan established by his employer. The disability plan resulted from a negotiated labor contract. The disability benefits were not paid pursuant to a State worker's compensation…

2Cases cited15 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Pallottini v. CommissionerUnited States Tax Court · 1988
  4. Marcello v. CommissionerUnited States Tax Court · 1964
  5. Estate of Mandels v. CommissionerUnited States Tax Court · 1975

10 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Sa v. DirectorNew Jersey Tax Court · 2012

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