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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.
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