T.C. Memo. 1997-426 UNITED STATES TAX COURT D. SAM SCHEELE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11469-95. Filed September 22, 1997. R determined a deficiency in tax and a penalty because P omitted from gross income an amount received pursuant to a series of agreements relating to a partnership that had prevailed in a lawsuit and in which P was a partner. P claimed that he received the payment in consideration for giving up his claim for damages on account of personal injuries. 1. Held: P has failed to prove that the payment was in settlement of a claim for damages on account of personal injuries. 2. Held, further, P is liable for the penalty under sec. 6662(a). Wesley W. Kirtley, for petitioner. Catherine J. Caballero, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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