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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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