T.C. Memo. 1996-405
UNITED STATES TAX COURT
LAWRENCE L. AND KATHLEEN J. KELTER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6209-95. Filed September 3, 1996.
P sustained work-related injuries to his hands.
For that reason, the pension plan of which P was a
member distributed to P 100 percent of his accrued plan
benefit. R determined a deficiency in income tax based
on Ps' failure to include that distribution in gross
income. Ps argue that the distributions are excludable
from gross income under sec. 105(c), I.R.C.
Held: The distributions are not excludable from
gross income under sec. 105(c), I.R.C., because the
amount of the distribution was not computed with
reference to the nature of the injuries sustained by P.
John F. Daniels III, for petitioners.
Katherine Holmes Ankeny, for respondent.
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