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Petitioners also stress that IRS employees advised them that
disability benefits are not taxable. Neither the Commissioner
nor this Court is bound by advice given to a taxpayer which is
based upon a mistake of law. Dixon v. United States, 381 U.S. 68
(1965); Auto. Club v. Commissioner, 353 U.S. 180 (1957). The
authoritative sources of Federal tax law are the statutes,
regulations, and judicial decisions. Zimmerman v. Commissioner,
71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d
1294 (2d Cir. 1979). We have applied the relevant statute, and
we have concluded that respondent correctly applied the law in
this case.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011