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OPINION
THORNTON, Judge: Respondent determined a $2,376 deficiency
in petitioners’ 1999 Federal income tax. After concessions, the
only issue for decision is whether Social Security disability
insurance benefits that Mr. Reimels received in 1999 are
excludable from petitioners’ income under section 104(a)(4).1
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. We incorporate herein the stipulated facts. When
petitioners filed their petition, they resided in Hicksville,
New York.
From September 25, 1968, to September 1, 1974, Mr. Reimels
served in the U.S. Armed Forces. He was highly decorated for his
combat service in Vietnam. While serving there, he was exposed
to Agent Orange, an instrumentality of war.2
After serving in Vietnam, Mr. Reimels was employed in the
private sector until February 19, 1993, when he was diagnosed
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable year in issue,
and Rule references are to the Tax Court Rules of Practice and
Procedure.
2 Agent Orange is an herbicide and defoliant that was used
widely in the Vietnam conflict. It contains dioxin and has been
shown to possess residual postexposure carcinogenic and
teratogenic properties in humans. PDR Medical Dictionary (2d ed.
2000).
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