George and Kathleen Knevelbaard, et al. - Page 2

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                  Kelly Mulholland and Andrew Gottlieb, for respondent.                               


                           MEMORANDUM FINDINGS OF FACT AND OPINION                                    
                  PARR, Judge:  Respondent determined the following                                   
            deficiencies in petitioners’ Federal income tax for the 1990 tax                          
            year:                                                                                     
            Docket No.             Petitioners                          Deficiency                    
            21366-94          George and Kathleen Knevelbaard           $6,592                        
            21981-94          Wilbur E. and Irene R. Gomes              23,294                        
            22527-94          Sam S. and Cynthia L. Kooistra            1,404                         
            22528-94          Walter H. and Helen Joan Brown            2,393                         
            22529-94          Arnold Leroy and Rosemary Souza           2,646                         
            22530-94          Vernon C. and June C. Christian           1,680                         
            22531-94          Phillip A. and Llyn Souza                 5,349                         
                  All section references are to the Internal Revenue Code in                          
            effect for the years in issue, and all Rule references are to the                         
            Tax Court Rules of Practice and Procedure, unless otherwise                               
            indicated.                                                                                
                  The issue is whether payments received by petitioner dairy                          
            farmers from various Bank Defendants in settlement of a lawsuit                           
            are excludable from gross income as compensation for personal                             
            injuries under section 104(a)(2).  We hold they are.                                      
                                         FINDINGS OF FACT                                             
                  Some facts have been stipulated and are so found.  The                              
            stipulation of facts and attached exhibits are incorporated                               
            herein by this reference.  When their petitions were filed, all                           
            petitioners resided in California.                                                        





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