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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax for the taxable year 2002 in the amount of $3,011.
The only issue for decision by the Court is whether certain
workers’ compensation benefits received by petitioner Sandra L.
Flores (Mrs. Flores) are taxable as though they were Social
Security benefits. We hold that they are by virtue of section
86(d)(3).
Background
Some of the facts have been stipulated, and they are so
found.
At the time that the petition was filed, petitioners resided
in Las Vegas, Nevada.
The facts are not in dispute.
In October 2000, Mrs. Flores was seriously injured at work
while employed by Citibank. As a result of her injury, Mrs.
Flores began receiving workers’ compensation benefits in November
2000. Mrs. Flores continued to receive workers’ compensation
benefits in 2002, which she received by check biweekly.
At the time of her injury in October 2000, Mrs. Flores was
also covered by a long-term disability policy through her
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