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pursuant to the Commissioner’s policy to exclude from income most
Government benefits and other welfare payments. That set of
revenue rulings comprises Rev. Rul. 63-136, 1963-2 C.B. 19
(benefit payments made to individuals undergoing employment
training or retraining under certain Federal acts dealing with
unemployment and underemployment), Rev. Rul. 57-102, 1957-1 C.B.
26 (payments to the blind), Rev. Rul. 74-74, 1974-1 C.B. 18
(awards to crime victims and their dependents), Rev. Rul. 74-205,
1974-1 C.B. 21 (replacement housing payments to aid displaced
individuals and their families), Rev. Rul. 75-271, 1975-2 C.B. 23
(assistance payments to lower income families enabling them to
acquire homes), and Rev. Rul. 98-19, 1998-1 C.B. 840 (relocation
payments made to flood victims).
Respondent distinguishes the payments addressed in those
rulings from distributions made under the CWT program on the
ground that a recipient must work in order to receive a
distribution in the latter case. That, argues respondent, places
the payment squarely within the definition of income found in
section 61 and section 1.61-2(a)(1), Income Tax Regs.
Respondent also relies on Rev. Rul. 65-18, 1965-1 C.B. 32.
That ruling addresses the inclusion in income of remuneration a
patient or member receives for the work he performs for the
Veterans’ Administration under 38 U.S.C. section 618 (Supp. V,
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