- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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