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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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