T.C. Memo. 1998-406
UNITED STATES TAX COURT
PHILLIP LEE ALLEN AND CAROLYN F. ALLEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 243-97. Filed November 13, 1998.
Joseph E. Mudd and Jeri L. Gartside, for petitioners.
Andrew H. Lee, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioners’ Federal income tax for 1991 of $39,697 and an
accuracy penalty in the amount of $7,939.
The issues for our consideration are: (1) Whether
petitioners are entitled to nonrecognition treatment on the
$130,000 settlement payment received from Allstate Insurance Co.
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