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HAYES v. COMMISSIONER

Docket No. 4534-96.

73 T.C.M. 2734 (1997)

T.C. Memo. 1997-213

Tommy Jean Hayes v. Commissioner.

United States Tax Court.

Filed May 7, 1997.

Attorney(s) appearing for the Case

Tommy Jean Hayes, pro se. Eric D. Stenson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Tommy Jean Hayes petitioned the Court to redetermine respondent's determination of a $50,200 deficiency in her 1992 Federal income tax and a $2,448 addition thereto under section 6651(a)(1). Following concessions, the only remaining issue is whether section 104(a)(2) allows petitioner to exclude from her gross income $220,723 of settlement proceeds received from State Farm Insurance Co. (State Farm). We...

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