William D. and Joyce M. Reimels - Page 3

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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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