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GRIFFIN, III v. COMMISSIONER

Docket No. 12900-98.

81 T.C.M. 972 (2001)

T.C. Memo. 2001-5

Wade H. Griffin, III v. Commissioner.

United States Tax Court.

Filed January 9, 2001.

Attorney(s) appearing for the Case

William E. Frantz, Atlanta, Georgia, Brenda G. Bates, and Donald P. Edwards (specially recognized), for the petitioner.

David R. Mackusick and Gwendolyn C. Walker, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent, for petitioner's 1994 taxable year, determined a $1,443,439 income tax deficiency and an accuracy-related penalty under section 6662(a),1 in the amount of $19,253. The parties have resolved some of the adjustments that were in controversy, and the following issues remain for our consideration: (1) Whether any portion of a $4,997,896 lawsuit settlement is excludable...

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