Stanley K. and Sandra B. Evanko - Page 10




                                        - 9 -                                         
          Petitioners have pointed to no court decision that comports with            
          their interpretations.                                                      
               In view of the foregoing, we hold that no portion of the               
          JROTC pay that petitioner received from the State of Hawaii                 
          Department of Education is excludable from gross income.                    
               We have considered all of the other arguments made by                  
          petitioners, and, to the extent that we have not specifically               
          discussed them above, we conclude those arguments are without               
          merit.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.3                         
                                                                                     
















               3In the reduced amount to which the parties agreed.                    





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