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BENT v. COMMISSIONER

Docket No. 11963-80.

87 T.C. 236 (1986)

JAMES EDWARD BENT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 28, 1986.

Attorney(s) appearing for the Case

James Edward Bent, pro se.

Joellyn R. Cattell, for the respondent.

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioner for 1977 in the amount of $5,402.38. After concessions by respondent, the issues for decision are as follows:

(1) Whether a $24,000 settlement payment to petitioner from Marshallton-McKean School District, in settlement of litigation, is excludable from gross income under section 104(a)(2);

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