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Thomas D. Tuka, pro se.
Julia L. Wahl, for respondent.
RUWE, Judge: Respondent determined a deficiency of $19,565
in petitioner’s Federal income tax for 1999 and an accuracy-
related penalty under section 6662(a)1 of $3,913. Respondent
concedes the accuracy-related penalty, and the issue for decision
is whether certain disability benefits that petitioner received
in 1999 were properly excluded from gross income under section
104(a)(3).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition herein, petitioner resided in Beaver Falls,
Pennsylvania.
Petitioner was employed as an airline pilot for U.S.
Airways, Inc., from 1972 until July 1995, when he left work
because of carpal tunnel syndrome. U.S. Airways paid petitioner
hourly wages. The hourly rate of compensation was established in
collective bargaining negotiations between U.S. Airways and the
Airline Pilots Association (ALPA). Petitioner’s disability
1All section references are to the Internal Revenue Code in
effect for the taxable year at issue.
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