Roosevelt Wallace - Page 1

                                   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’                 

               Thomas Stylianos, Jr., for petitioner.                                 
               Nina P. Ching, for respondent.                                         

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Last modified: November 10, 2007