- 11 - interest on such amount. Simply put, these aspects of the case raise serious doubts that petitioner is correct in his assertion that the Dupont/Universal payment was made exclusively "on account of personal injuries or sickness". Commissioner v. Schleier, supra at 336-337. In his motion, petitioner asked "in the alternative for a determination of material facts not in substantial controversy, and for an order specifying those facts". As we indicated supra footnote 2, the facts set forth in this opinion are solely for the purpose of deciding the motion. Nevertheless, it appears from the record that many of the facts are not in dispute, and the Court encourages the parties to stipulate facts to the fullest extent possible. See Rules 91, 122. Consistent with the preceding discussion, we shall deny petitioner's Motion for Partial Summary Judgment. To reflect the foregoing, An order will be issued denying petitioner's Motion for Partial Summary Judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011