Roosevelt Wallace - Page 2




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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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