T.C. Memo. 1997-542
UNITED STATES TAX COURT
CHERYL DENESE BREWER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8612-96. Filed December 9, 1997.
Cheryl Denese Brewer, pro se.
Jason M. Silver, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $47,047 deficiency in
petitioner's 1992 Federal income tax.
The issues for decision are: (1) Whether petitioner is
entitled to exclude from gross income amounts received in
settlement of a class action suit pursuant to section 104(a)(2),
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