T.C. Memo. 1998-291
UNITED STATES TAX COURT
FRANKLIN P. AND NONA COADY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4722-97. Filed August 6, 1998.
Lance A. Hulbert, for petitioners.
Gregory M. Hahn, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court fully
stipulated. See Rule 122. Franklin P. and Nona Coady petitioned
the Court to redetermine respondent's determination of a $49,531
deficiency in their 1994 Federal income tax. Following
concessions, we must decide whether petitioners' 1994 gross
income includes $373,307 that was awarded to Ms. Coady as
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