- 2 - Addition to Tax Penalty Year Deficiency Sec. 6661 Sec. 6662(a) 1988 $8,760 $2,190 --- 1989 2,423 --- $485 1990 7,532 --- 1,506 Petitioners have alleged and claimed in their petition that, based on their amended Federal income tax returns for 1988, 1989, and 1990, they are entitled to refunds for those years in the amounts of $896, $1,567, and $1,574, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by respondent,1 the issues to be decided are: (1) Whether all or any part of the payments received in the years 1988 through 1990 by petitioner William J. Goeden from State Central Credit Union, pursuant to a settlement agreement, is excludable from gross income under section 104(a)(2) as damages received on account of personal injuries; (2) whether petitioners are entitled to deduct any part of attorney's fees 1 Respondent has conceded that the value of health and life insurance coverage received by petitioner from State Central Credit Union during the years in issue is excludable from gross income. Respondent has also conceded that, to the extent attorney's fees were paid in 1988 for the purpose of obtaining taxable income, petitioners are entitled to deduct such fees as a miscellaneous itemized deduction in that year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011