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service. If the employee has less than 15 years of pension
credit, he may qualify for a "special past service pension".
To qualify for a disability pension under the plan, the
employee must: (a) Have at least 1,000 hours of work in "Covered
Employment" without a permanent break in covered employment; and
(b) be totally disabled and awarded a Social Security or Railroad
Retirement Disability Benefit before age 65. If the employee
qualifies for the disability pension, the amount of the
disability pension "is calculated in the same way as the Age
Pension." (Emphasis added.) Under the plan, "When a Disability
Pensioner reaches age 65, pension benefits will automatically
become an Age Pension". Petitioner was determined to be totally
disabled under the pension plan and to be qualified for a
disability pension.
During 1999, petitioner received pension payments of
$20,115. The Pension reported the pension payments as income on
Form 1099-R, Distributions From Pensions, Annuities, Retirement
or Profit-Sharing Plans, IRAs, Insurance Contracts, etc. Federal
income tax of $127.04 was withheld from the pension
distributions.
Petitioners reported "Total pensions and annuities" of
$20,116 on line 16a of their Federal income tax return but line
16b of the return, "Taxable amount", was left blank. Petitioners
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Last modified: May 25, 2011