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other occasions, and we have held that interest paid on damages awarded in
connection with personal injury claims is taxable and not excludable from
income, but that the amount of the attorney's fees paid in connection with the
interest award is deductible from income. Kovacs v. Commissioner, 100 T.C.
124, 128-130 (1993), affd. without published opinion 25 F.3d 1048 (6th Cir.
1994); Aames v. Commissioner, 94 T.C. 189, 192 (1990); Riddle v. Commissioner,
27 B.T.A. 1339, 1341 (1933). We, therefore, hold that the interest received
by petitioner on the amount of the judgment in the IBP case is taxable income
that is not excludable under section 104(a)(2).
Decision will be entered
under Rule 155.
Reviewed by the Court.
HAMBLEN, CHABOT, COHEN, SWIFT, JACOBS, GERBER, WRIGHT, PARR, WELLS,
RUWE, WHALEN, COLVIN, HALPERN, BEGHE, CHIECHI, LARO, AND FOLEY, JJ., agree
with this opinion.
VASQUEZ, J., did not participate in the consideration of this opinion.
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