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excludable under section 105(c)(1). We conclude that the
disability payments petitioner received in 1997 are not
excludable from petitioners’ income under section 105(c).
C. Conclusion
Petitioner’s disability payments are includable in income
under section 105(a) and are not excludable from income under
section 104(a)(3) or section 105(c). Thus, petitioners
underreported their 1997 income by $9,149.
Decision will be
entered for respondent.
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Last modified: May 25, 2011