Roosevelt Wallace - Page 9




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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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