SEAY v. COMMISSIONER

Docket No. 2906-70.

58 T.C. 32 (1972)

DUDLEY G. SEAY AND SYBIL R. SEAY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 10, 1972.


Attorney(s) appearing for the Case

John M. Byers and Gerald J. Kahn, for the petitioners.

Denis J. Conlon and Robert F. Brunn, for the respondent.


SIMPSON, Judge:

The respondent determined a deficiency of $26,066.60 in the petitioners' 1966 Federal income tax. The only issue for decision is whether $45,000 of a $105,000 payment, which one of the petitioners received in settlement of claims against his former employer, is excludable from gross income as damages received on account of personal injuries.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found...

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