T.C. Memo. 1998-453
UNITED STATES TAX COURT
MANUEL J. SERPA, JR. AND PATRICIA A. SERPA, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8209-94. Filed December 28, 1998.
Lewis J. Paras, for petitioners.
Carmino J. Santaniello, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: Respondent determined that petitioners had a
$12,017 deficiency in income tax for 1991. The sole issue for
decision is whether part of the $150,000 petitioners 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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