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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.
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