D. Sam Scheele - Page 1

                                 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.                                







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