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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
penalty.
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
Procedure.
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).
Background
Introduction
Petitioner resided in Grants Pass, Oregon, at the time the
petition was filed.
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