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ROSEN v. UNITED STATES

Civ. A. No. 84-0074-C.

646 F.Supp. 97 (1986)

Kenneth S. ROSEN and Lou Hill ("Johnnye") Davidson, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Virginia, Charlottesville Division.

September 23, 1986.

Attorney(s) appearing for the Case

Robert E. Stroud, D. French Slaughter, III, McGuire, Woods & Battle, Charlottesville, Va., for plaintiffs.

Stephen Carlton, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., John Perry Alderman, U.S. Atty., Roanoke, Va., for defendant.

MEMORANDUM OPINION

MICHAEL, Judge.

Kenneth S. Rosen [hereinafter "taxpayer"] and his wife, Lou Hill Davidson,1 brought this suit seeking to recover $20,755.00 in income taxes paid for the calendar year 1976 and $168,221.00 in income taxes paid for the calendar year 1977. The question presented is whether the sums received by taxpayer upon termination of his employment due to disability should be included in gross income. It is...

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