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104(a)(1) as amounts received under a worker's compensation act
or a statute in the nature of a worker's compensation act. We
hold that they are not.
2. Whether the $7,101 is excluded from income for 1992 on
the grounds that Pawtucket and respondent violated the Americans
with Disabilities Act of 1990 (ADA), Pub. L. 101-336, sec. 2, 104
Stat. 328 (current version at 42 U.S.C. sec. 12101 (1994)). We
hold that it is not.
3. Whether including the $7,101 in petitioner's income is
unfair discrimination. We hold that it is not.
The parties submitted this case fully stipulated. Rule 122.
Section references are to the Internal Revenue Code. Unless
otherwise indicated, Rule references are to the Tax Court Rules
of Practice and Procedure.
Background
A. Petitioner
Petitioner lived in the city of Pawtucket, Rhode Island
(Pawtucket), when he filed the petition in this case. He was
born on May 11, 1935.
Petitioner began employment as a firefighter with Pawtucket
on May 14, 1961. During his career as a firefighter, petitioner
received several promotions and rose to the rank of lieutenant.
He was a member of the International Association of Firefighters,
Local No. 1261 (the union) from 1961 to September 4, 1992.
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