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MILLER v. COMMISSIONER

Docket No. 21113-87.

93 T.C. 330 (1989)

BONNIE A. MILLER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 13, 1989.

Attorney(s) appearing for the Case

S. Ronald Ellison, for the petitioner.

Robert E. Williams, Jr., for the respondent.

OPINION

WELLS, Judge:

Respondent determined a deficiency of $249,106 and an addition to tax pursuant to section 66611 of $62,254 against petitioner for 1983.

The instant case stems from petitioner's receipt of $525,000 in settlement of two defamation actions. We must decide (1) whether the settlement proceeds should be excluded from gross income pursuant to section 104...

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