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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.
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Last modified: May 25, 2011