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.
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