Robert J. and Anne L. Wilson - Page 9

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          Assistant Attorney General/Chief Counsel.  In the letter, the AAG           
          noted that $42,396 of the $104,000 settlement had been deposited            
          with the circuit court, leaving the remainder, or $61,604, to be            
          paid.  He also noted that the $61,604 accrued postjudgment                  
          interest at 10 percent per annum from September 20, 1989, until             
          actually paid; furthermore, he noted that, the "settlement                  
          includes all prejudgment interest."   Finally, the AAG indicated            
          that the prejudgment interest included in the settlement was                
          $34,618.                                                                    
               On December 7, 1989, the State deposited with the circuit              
          court $62,937.35 in full payment of the agreement entered into on           
          September 20, 1989; this amount included the balance of $61,604             
          due on the consent inquisition, and postjudgment interest of                
          $1,333.35 through December 8, 1989.  However, a schedule attached           
          to the letter which included the foregoing deposit indicated that           
          no prejudgment interest was due and payable.                                
               On January 10, 1990, petitioner petitioned the circuit court           
          to withdraw the $13,996 and 62,937.35 previously deposited by the           
          State, or $76,933.35, plus interest thereon.  On January 11,                
          1990, the clerk of the circuit court issued a check to petitioner           
          for $79,094.05, which included $76,933.35 previously deposited by           
          the State and interest of $2,160.70.                                        
               From 1980 through the taxable years in issue, petitioners              
          did not report on their Federal tax returns any of the                      
          condemnation proceeds received from the State, nor did they                 




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