128 T.C. No. 11
UNITED STATES TAX COURT
ROOSEVELT WALLACE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4637-03. Filed April 16, 2007.
P participated in a compensated work therapy
program administered by the U.S. Department of Veterans
Affairs (VA) and, on account thereof, received a
distribution of $16,393 from the VA Special Therapeutic
and Rehabilitation Activities Fund. R increased P’s
gross income by that amount on the ground that the
distribution is a payment for services. P claims that
the distribution is a tax-exempt veterans’ benefit
pursuant to I.R.C. sec. 139(a)(3) and 38 U.S.C. sec.
5301 (2000).
Held: The distribution is a tax-exempt veterans’
benefit.
Thomas Stylianos, Jr., for petitioner.
Nina P. Ching, for respondent.
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Last modified: November 10, 2007