William E. Levesque - Page 12




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          benefits.  Petitioner cited no authority that anyone whose                  
          benefits were structured like his was treated differently than              
          our holding here.  We conclude that petitioner's discrimination             
          claim lacks merit.                                                          
          D.   Conclusion                                                             
               We conclude that the pension payments of $7,101 that                   
          petitioner received in 1992 are not excludable from income under            
          section 104(a)(1).                                                          
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          




























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