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from income a $99,434 lump-sum payment received by Ronald Neil
Robinson (petitioner) from the United States Army.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Sometime before October 1990, petitioner was diagnosed with
depression and began receiving medical treatment for that
condition. On September 30, 1992, petitioner was released from
active duty in the United States military due to his
participation in a “VOLUNTARY INCENTIVE PROGRAM-SSB”. Petitioner
received $99,434.30 in a lump-sum payment.
By letter dated July 29, 1993, the Department of Veterans
Affairs notified petitioner that his claim for disability
compensation for neurosis had been approved. Petitioner’s claim
for disability compensation payments was approved as follows:
Monthly Rate Effective Date
$83 11/1/92
85 12/1/92
The disability award was made subject to the recoupment of
$99,434.30 that petitioner had received due to his separation
from service with the military.
Petitioners included $99,434 in their gross income on their
Form 1040, U.S. Individual Income Tax Return, for 1992. On an
amended return received by the Austin Service Center on March 20,
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