T.C. Memo. 1996-465
UNITED STATES TAX COURT
DIAMOND CLAIMS & INVESTIGATION SERVICES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5736-93. Filed October 16, 1996.
Merritt S. Yoelin and Michael D. Walker, for petitioner.
Shirley M. Francis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$234,870.48 in petitioner's Federal income tax for its taxable
year ended September 30, 1988.
The only issue remaining for decision is whether petitioner
must include in its income for the year at issue all, or only a
portion, of the amount awarded by the U.S. District Court for the
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