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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