- 2 - 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.Page: Previous 1 2 3 4 5 6 7 Next
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