George L. Willis and D. Thomas-Willis - Page 3

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          their petition was filed.  Hereafter, references to petitioner in            
          the singular shall denote George L. Willis.                                  
               On July 3, 1985, petitioner suffered a career-ending back               
          injury while performing services as a longshoreman in the employ             
          of Matson Terminals, Inc. (Matson).  As a result of petitioner's             
          back injury, and in accordance with the Longshore and Harbor                 
          Workers' Compensation Act (currently codified at 33 U.S.C. secs.             
          901-950 (1994)), Matson paid worker's compensation benefits to               
          petitioner for temporary disability from July 4, 1985, to July 8,            
          1991, and for permanent disability from July 9, 1991, through and            
          including taxable year 1992.2                                                
               In addition to receiving worker's compensation benefits                 
          during 1992, petitioner received Social Security disability                  
          benefits.  A Notice of Award dated January 4, 1991, from the                 
          Office of Disability and International Operations of the Social              
          Security Administration, announced that petitioner was "entitled             
          to monthly disability benefits from Social Security beginning                
          March 1990."  However, the notice explained:                                 




          2    In 1993, petitioner and Matson reached a settlement                     
          resolving petitioner's worker's compensation claim relating to               
          his 1985 injury as well as a claim relating to a 1980 injury.                
          Matson paid the settlement amount due to petitioner in 1993.  The            
          parties have stipulated that the settlement of petitioner's                  
          worker's compensation claims in 1993 did not affect his worker's             
          compensation benefits or Social Security disability benefits paid            
          in prior years.                                                              




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