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WOODS v. COMMISSIONER

Docket Nos. 12783-94, 12784-94.

76 T.C.M. 980 (1998)

T.C. Memo. 1998-435

Michael J. and Carrie L. Woods v. Commissioner. Jacquelyn Woods v. Commissioner.

United States Tax Court.

Filed December 10, 1998.

Attorney(s) appearing for the Case

Arthur I. Fixler, Providence, R. I., for the petitioners. Carmino J. Santaniello, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

Respondent determined that petitioners Michael J. and Carrie L. Woods had a $13,454 deficiency in income tax for 1992, and that petitioner Jacquelyn Woods had a $190,777 deficiency in income tax for 1992.

The sole issue for decision is whether part of the proceeds petitioners received in settlement of a tort action is prejudgment interest, and, if so, whether it is excludable from gross income as damages for a personal...

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