120 T.C. No. 1 UNITED STATES TAX COURT THOMAS D. TUKA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12224-01. Filed January 6, 2003. P excluded from gross income certain disability benefits that he received under a pilot disability plan funded by his employer, U.S. Airways, Inc. P alleges that in prior collective bargaining negotiations, the Airline Pilots Association and U.S. Airways pilots made wage concessions in exchange for the pilot disability plan. P argues that, in reality, the concessions he and the other pilots made represent the contributions to the pilot disability plan for purposes of sec. 104(a)(3), I.R.C. Held: P’s employer, U.S. Airways, funded the pilot disability plan for purposes of sec. 104(a)(3), I.R.C. Contributions to the plan were not includable in P’s gross income. Accordingly, the disability benefits are not excluded under sec. 104(a)(3), I.R.C.Page: 1 2 3 4 5 6 7 Next
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