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P & X MKTS., INC. v. COMMISSIONER

Docket No. 15836-95.

106 T.C. 441 (1996)

P & X MARKETS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 13, 1996.

Attorney(s) appearing for the Case

Marvin B. Starr, for petitioner.

Margaret A. Martin, for respondent.

OPINION

LARO, Judge:

The case is before the Court on respondent's motion for summary judgment.1 Respondent moves for summary adjudication in her favor, arguing that proceeds received by petitioner in settlement of a lawsuit are not within section 104(a)(2) for lack of a personal injury. Respondent supports her motion with the pleadings and the following exhibits: (1) Petitioner's 1989 Form 1120, U.S. Corporation Income...

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