BURNS v. COMMISSIONER

No. 11924-04.

94 T.C.M. 276 (2007)

T.C. Memo. 2007-271

Sara J. Burns v. Commissioner.

United States Tax Court.

September 12, 2007.


Attorney(s) appearing for the Case

John W. Sunnen, for petitioner.

Eric K. Huss, for respondent.


MEMORANDUM OPINION

CARLUZZO, Special Trial Judge:

In a notice of deficiency dated April 13, 2004, respondent determined a $41,723 deficiency in petitioner's 1999 Federal income tax. The issue for decision is whether a reward payment (the reward) petitioner was entitled to receive in 1999 is includable in her income for that year even though in a bankruptcy proceeding initiated by petitioner the reward was determined to be subject to the claim of a creditor...

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