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ROSARIO v. COMMISSIONER

Docket No. 1378-00.

83 T.C.M. 1376 (2002)

T.C. Memo. 2002-70

Antonio Rosario and Joyce Rosario v. Commissioner.

United States Tax Court.

Filed March 26, 2002.

Attorney(s) appearing for the Case

Robert J. Fedor, for the petitioners.

Katherine Lee Kosar, for the respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $90,454 in petitioners' Federal income tax for 1993. The issues for decision are whether $242,556 received by petitioner Antonio Rosario from Jesse Holman Jones Hospital (the hospital) in 1993 is taxable income to him in 1993 and whether the period of limitations expired for the 1993 taxable year.

Background

The parties...

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