ANDERSON v. COMMISSIONER

Docket No. 13327-97.

80 T.C.M. 657 (2000)

T.C. Memo. 2000-344

Richard D. Anderson and Mary L. Anderson v. Commissioner.

United States Tax Court.

Filed November 8, 2000.


Attorney(s) appearing for the Case

Robert H. Hishon, Atlanta, Georgia, for the petitioners. Roslyn D. Grand, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined income tax deficiencies of $30,747 and $18,940 for petitioners' 1993 and 1994 tax years, respectively. The issue for our consideration is whether amounts received by petitioners in connection with an action for tortious interference with business relations are excludable from petitioners' income under section 104(a)(2).

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