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was terminated. Indeed, he simply failed to present any evidence
that the settlement he received included a settlement of a tortlike
cause of action on account of personal injuries or sickness.
We have considered all of petitioners' other arguments and, to
the extent not discussed above, find them to be without merit.
In sum, the entire $1,125,000 settlement payment petitioner
received is includable in petitioners' 1989 gross income.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011