MEMORANDUM OPINION
HALPERN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for his 1989 taxable year of $67,883 and a penalty under section 6662(a) of $13,577. The issues we must decide are (1) whether petitioner may exclude an amount from gross income as damages received on account of personal injuries and (2) whether petitioner is liable for the penalty.
Unless otherwise noted, all section references are to the Internal...
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