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GIBSON v. COMMISSIONER

Dkt. No. 13125-05.

94 T.C.M. 164 (2007)

T.C. Memo. 2007-224

Douglas A. Gibson v. Commissioner.

United States Tax Court.

August 13, 2007.

Attorney(s) appearing for the Case

Dwight M. Montgomery, for petitioner.

Laura A. McKenna, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a $49,778 deficiency in petitioner's 2002 Federal income tax and a $9,956 section 6662 penalty for 2002.1 After a concession,2 the issues remaining for decision are (1) whether $175,000 petitioner received during 2002 in connection with a settlement of a lawsuit is excludable from gross income pursuant to section 104(a)...

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