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BROWN v. COMMISSIONER

Docket No. 20910-88.

57 T.C.M. 1557 (1989)

T.C. Memo. 1989-475

Harvey B. and Gloria Brown v. Commissioner.

United States Tax Court.

Filed August 31, 1989.

Attorney(s) appearing for the Case

Harvey B. and Gloria Brown, pro se. Pamela S. Wilson, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $3,400 in petitioners' Federal income tax for 1985. The issue to be decided is whether disability payments, which petitioner Gloria Brown received from the State of California in 1985, are in the nature of unemployment compensation and taxable under section 85.1

All of the facts are stipulated. At the time the petition was filed...

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