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BROWNHOLTZ v. COMMISSIONER

Docket No. 2443-77.

71 T.C. 332 (1978)

WILLIAM W. BROWNHOLTZ AND ANNA M. BROWNHOLTZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 4, 1978.

Attorney(s) appearing for the Case

William W. Brownholtz and Anna M. Brownholtz, pro se.

Carolyn M. Parr, for the respondent.

RAUM, Judge:

The Commissioner determined a deficiency in petitioners' 1973 Federal income taxes in the amount of $1,520.40. Petitioners received U.S. Civil Service disability retirement annuity payments during 1973. The only issue to be decided is whether petitioners may exclude from gross income a portion of the payments as sick pay under section 105(d),1 while excluding the remainder in...

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