§21151

ection 1 .104-1(b), Income Tax Regs ., the distributions are not excludable from gross income . Petitioner argues that the distributions nevertheless qualify for exclusion from gross income because they were made under Cal . Govt . Code (West 2003), section 21151 . Petitioner contends that Cal . Govt . Code section 21151 is akin to a worker's compensation because it conditions eligibility for benefits on the existence of a work-related injury or sickness, called "industrial disability" under the