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OPINION
HALPERN, Judge: Respondent determined a deficiency of
$2,460 in petitioner’s 2000 Federal income tax. The sole issue
for decision is whether $16,393 received by petitioner during
2000 in connection with his participation in a work therapy
program administered by the U.S. Department of Veterans Affairs
(VA) is includable in his gross income for 2000. We hold that it
is not.
Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for 2000.
Background
Introduction
This case was submitted for decision without trial pursuant
to Rule 122, Tax Court Rules of Practice and Procedure. Facts
stipulated by the parties are so found. The stipulation of facts
filed by the parties, with attached exhibits, is included herein
by this reference.
Residence
At the time the petition was filed, petitioner resided in
Lowell, Massachusetts.
Participation in Compensated Work Therapy
During 2000, pursuant to a physician’s prescription,
petitioner participated in (and completed) a VA-administered
therapeutic and rehabilitative work program. As part of his
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