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THOMAS v. COMMISSIONER

Docket No. 17397-99.

81 T.C.M. 1653 (2001)

T.C. Memo. 2001-120

Will L. and Rachel A. Thomas v. Commissioner.

United States Tax Court.

Filed May 21, 2001.

Attorney(s) appearing for the Case

Rachel A. Thomas, pro se.

Linda M. Davis, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

Respondent determined a deficiency of $1,432 in petitioners' 1997 Federal income tax.1

The sole issue for decision is whether Social Security disability benefits received by petitioner Will L. Thomas (petitioner) during 1997 are includable in gross income under section 86(a), or whether, as petitioners contend, such benefits are excludable from gross income under sections...

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