- 6 - petitioner's gross income for 1994 includes only the following items: Wages $2,738 Vacation pay 8,845 Short-term disability 6,000 Long-term disability 10,124 CALPERS 40,635 Corrected gross income 68,342 OPINION Whether the disability benefits paid to petitioner in 1994 are subject to Federal income tax as respondent claims or are excludable in whole or in part from petitioner's income as petitioner claims requires an examination of sections 104, 105, and 106. Respondent contends that the benefits in question are includable in income under section 105(a). Petitioner argues generally that the benefits are not taxable. Although petitioner does not cite specific sections to support his position, it is clear on the record before us that, if the benefits are excludable from income, it is only because the requirements of either section 104(a)(3) or section 105(c) are met.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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