D. Sam Scheele - Page 2

                                        - 2 -2                                        
                                 MEMORANDUM OPINION                                   
               HALPERN, Judge:  Respondent determined a deficiency in                 
          petitioner's Federal income tax for his 1989 taxable year of                
          $67,883 and a penalty under section 6662(a) of $13,577.  The                
          issues we must decide are (1) whether petitioner may exclude an             
          amount from gross income as damages received on account of                  
          personal injuries and (2) whether petitioner is liable for the              
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts filed by the parties, with accompanying            
          exhibits, is incorporated herein by this reference.  We need find           
          few facts in addition to those stipulated; accordingly, we shall            
          not separately set forth those findings and shall include our               
          additional findings of fact in the discussion that follows.                 
          Petitioner bears the burden of proof.  Rule 142(a).                         
               Petitioner resided in Grants Pass, Oregon, at the time the             
          petition was filed.                                                         

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011