Respondent determined a deficiency of $216.68 in the income tax of petitioners for the year 1950. The sole issue is whether a "disability pension" payment of $1,564.20 which Charles F. Brown received in said year from the Baltimore City Police Department, is exempt from tax under section 22 (b) (5) of the Internal Revenue Code of 1939. This section, so far as here material, excludes from gross income and exempts from tax, "amounts received, * * * under workmen's compensation...
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