What is the test for total and permanent disability?

1 Although revenue rulings do not have the force of law, they "do constitute a body of experience and informed judgment to which courts may properly resort for guidance in the interpretation of relevant revenue statutes and regulations." Watts v. United States, 703 F.2d 346, 350 n. 19 (9th Cir.1983).

2 We do not decide at this time the precise standard for determining total a permanent disability. A decision on that issue must await a case in which the issue is presented. For purposes of this appeal we need only decide that an inability to continue in one's chosen profession standing alone is not a total and permanent disability. See Watts v. United States, 703 F.2d 346, 351 n. 23 (9th Cir.1983) (distinguishing between "permanently disabled" and "totally and permanently disabled").