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ARMSTRONG v. COMMISSIONER

Docket Nos. 11177-92, 11178-92.

66 T.C.M. 1502 (1993)

T.C. Memo. 1993-579

Otis Armstrong and Yvonne D. Armstrong v. Commissioner.

United States Tax Court.

Filed December 8, 1993.

Attorney(s) appearing for the Case

Michael J. Sternick, 410 Seventeenth St., Denver, Colo., for the petitioners.

Robert A. Varra, for the respondents.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax of $53,675, $14,829, and $7,618, for taxable years 1987, 1988, and 1989, respectively. The Commissioner also determined a $13,410 addition to tax for 1987 pursuant to section 6651(a)(1).1 At issue is whether benefits received under the total and permanent disability provisions of the Bert Bell NFL Player Retirement Plan...

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