Franklin P. and Nona Coady - Page 1

                                 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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