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BEISLER v. C.I.R.

No. 85-7222.

787 F.2d 1325 (1986)

Randall L. BEISLER and Judith K. Beisler, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 18, 1986.

Attorney(s) appearing for the Case

Deborah M. Regan, Robert V. Atmore, Lindquist & Vennum, Minneapolis, Minn., for petitioners-appellants.

John Griffin, Michael Paup, Glenn Archer, Washington, D.C., for respondent-appellee.

Before TANG and WIGGINS, Circuit Judges, and WILLIAMS, District Judge.

WIGGINS, Circuit Judge.

Randall and Judith Beisler appeal from a Tax Court decision holding that payments Randall received from the Bert Bell NFL Retirement Plan (NFL Plan) are not excludable from gross income under 26 U.S.C. § 105(c)(1982). We have jurisdiction under 26 U.S.C. § 7482 (1982), and we affirm.

I. FACTS AND PROCEEDINGS BELOW

Randall played professional football from 1966 through 1975. In 1975, he injured his neck in an NFL...

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