On November 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Holland v. Commissioner (T.C. Memo. 2021-129). The primary issue presented in Holland was whether petitioner is taxable on retirement income he received during 2017. Held:  #Protester? Yes. #Winning? Not so much. Basics of Argument in Holland v. Commissioner Although the petitioner conceded that he retirement income received payments…he nonetheless asserted that such payments did not constitute “taxable income” because they were received in exchange for his prior labor and were “unconnected with his exercise of any Federal privilege.”     Background to Holland v. Commissioner The petitioner was retired during 2017. He had previously been employed as a service technician by PepsiCo. He drove a truck for a period of time and was a member of the Teamsters union. During 2017 petitioner received Social Security benefits of $26,292. The Social Security Administration (SSA) reported these…