On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to retire in 2012. Thereafter, the petitioner received Federal Employees Retirement System (FERS) disability income and Social Security Disability Insurance (SSDI) benefits. The petitioner did not claim a loss deduction on his timely filed return. Because of other income, the IRS sent a Notice CP2000 (proposed adjustments) regarding the petitioner’s 2015 return, and the petitioner responded timely. In the petitioner’s response, he cited serious illness and incapacitation. The petitioner conceded the additional income, but he contested…