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The issue for decision is whether a portion of the
compensation received by petitioner in his capacity as a Junior
Reserve Officers’ Training Corps (JROTC) instructor from a local
school district is excludable from gross income.2 We hold that
no portion of such compensation is excludable.
FINDINGS OF FACT
Most of the facts have been stipulated, and they are so
found. Petitioner resided in Houston, Texas, at the time that
his petition was filed with the Court.
Petitioner’s Career
After graduating from college, petitioner entered military
service in 1957 as a lieutenant in the U.S. Army. Twenty-six
years later, in 1983, petitioner retired from active duty as a
colonel, having attained that rank in 1979.
Upon retirement from active duty, petitioner became entitled
to receive retired pay from the Army. However, as a retired
military officer, petitioner was no longer entitled to receive
(and never in fact received) any military allowances, such as a
basic allowance for quarters, a basic allowance for subsistence,
or a variable housing allowance.
In August 1987, petitioner was hired by the Houston
Independent School District (HISD) as a JROTC instructor. Since
2 An adjustment to petitioner’s itemized deductions is a
mechanical matter, the resolution of which depends on our
disposition of the disputed issue. See sec. 67(a).
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