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The Judges’ Retirement Law is not a workers’ compensation
act, and it is not in its entirety a statute in the nature of a
workers’ compensation act. Nevertheless, benefits received under
the Judges’ Retirement Law may still qualify for exclusion if it
is a “dual-purpose statute”, as petitioners argue. See Neill v.
Commissioner, 17 T.C. 1015 (1951); Burgess v. Commissioner, T.C.
Memo. 1986-228, affd. without published opinion 822 F.2d 61 (9th
Cir. 1987); Craft v. United States, 879 F. Supp. 925 (S.D. Ind.
1995); Frye v. United States, 72 F. Supp. 405 (D.D.C. 1947). “A
dual-purpose statute is one which authorizes payments for work-
related, as well as non-work-related disabilities and may provide
other pension benefits.” Kane v. United States, 28 Fed. Cl. 10,
13 (1993), affd. 43 F.3d 1446 (Fed. Cir. 1994). To qualify as a
dual-purpose statute, the statute must contain some specific
provision which restricts the payment of benefits to cases of
work-related disabilities. Id. at 14; see also Rutter v.
Commissioner, supra at 468.
Petitioners argue that the Judges’ Retirement Law is a dual-
purpose statute because CGC section 75061(a) “has one provision
that provides for retirement based solely on injury or sickness
arising out of employment, and also one provision providing for
retirement based on years of service.” Respondent contends that
CGC section 75060 makes no distinction between injuries which are
work related and injuries which are not work related and that CGC
section 75061 modifies CGC section 75060 but does not add any new
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