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SIDORAN v. C. I. R.

No. 79-7255.

640 F.2d 231 (1981)

Paul and Alice J. SIDORAN, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 19, 1981.

Attorney(s) appearing for the Case

Robert M. Lantz, Jr., Seattle, Wash., on brief, for petitioners-appellants.

Gilbert E. Andrews, Washington, D.C., on brief, for respondent-appellee.

Before WRIGHT, NELSON, and NORRIS, Circuit Judges.

NORRIS, Circuit Judge.

Appellants, Paul and Alice Sidoran, appeal from a decision of the Tax Court finding deficiencies in income tax due in the taxable years 1974 and 1975.

The sole issue is whether appellants are entitled to exclude Paul Sidoran's Air Force retirement pay from income as "amounts received as a pension, annuity, or similar allowance for personal injuries or sickness resulting from active service in the armed forces of any country."

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