T.C. Memo. 1998-433
UNITED STATES TAX COURT
JOSEPH M. PERRY, Petitioner v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 24068-95. Filed December 10, 1998.
Joseph M. Perry, pro se.
Carmino J. Santaniello, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: Respondent determined that petitioner had a
$12,024 deficiency in income tax for 1990. The sole issue for
decision is whether part of the $137,437.50 petitioner received
in settlement of a tort action is prejudgment interest, and, if
so, whether it is excludable from gross income as damages for a
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