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with lung cancer. This illness resulted from his exposure to
Agent Orange during his Vietnam combat service.
On August 3, 1993, Mr. Reimels applied for disability
insurance benefits with the Social Security Administration,
claiming disability on account of his lung cancer. On
January 13, 1994, the Social Security Administration determined
that Mr. Reimels was entitled to disability insurance benefits.
On November 2, 1993, Mr. Reimels applied for service-
connected disability compensation with the Veterans’
Administration.3 On June 15, 1998, the Veterans’ Administration
awarded Mr. Reimels a “100 percent service connected disability”
on the basis of his exposure to Agent Orange and his diagnosis of
lung cancer.
In 1999, Mr. Reimels received $12,194 in disability
insurance benefits from the Social Security Administration. He
also received service-connected disability compensation from the
Veterans’ Administration, which petitioners allege totaled $2,246
per month.
On their 1999 joint Federal income tax return, petitioners
excluded from their gross income Mr. Reimels’s Social Security
3 In the Department of Veterans Affairs Codification Act,
Pub. L. 102-83, sec. 301, 105 Stat. 378 (1991), Congress
redesignated the Veterans’ Administration the Department of
Veterans Affairs. For convenience, we refer to the Veterans’
Administration, consistent with the language used in sec. 104.
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