CADE v. COMMISSIONER

Docket No. 22819-97.

78 T.C.M. 894 (1999)

T.C. Memo. 1999-394

Steven P. and Maureen Cade v. Commissioner.

United States Tax Court.

Filed December 3, 1999.


Attorney(s) appearing for the Case

Charles W. Becker, San Diego, California, for the petitioners.

Thomas A. Dombrowski, for the respondent.


MEMORANDUM OPINION

LARO, Judge:

This case is before the Court fully stipulated. See Rule 122. Respondent determined a $646,800 deficiency in petitioners' 1993 Federal income tax. Respondent later asserted in his amended answer that the deficiency was $651,000.

We must decide whether section 104(a)(2) allows petitioners to exclude from their gross income certain proceeds received in settlement of a lawsuit. We hold it does not. Unless otherwise indicated...

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