- 2 -
1992 258,998 $89,391 11,918
1993 31,871 --- 6,356
After concessions, the remaining issues for decision are:
(1) Whether amounts received by petitioners in 1992 pursuant to
settlement agreements were damages received on account of
personal injuries under section 104(a)(2),1 and (2) whether
petitioners are liable for a section 6662(a) penalty for 1992.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, the first
supplemental stipulation of facts, and the attached exhibits.
At the time of the filing of their petition, petitioner
Allen Burditt II resided in Houston, Texas, and petitioner Sarah
Maunee S. Burditt resided in Sante Fe, New Mexico.
Hereinafter, we shall refer to petitioner Allen Burditt II
as “petitioner” or “Mr. Burditt”, and references to "petitioners"
are to Allen Burditt II and Sarah Maunee S. Burditt.
From 1988 through 1993, petitioner was the president of
Carancahua Resources, Inc. (CRI), a Texas corporation, and
petitioners held a controlling interest in the corporation that
owned 80 percent of CRI's stock. In 1988, CRI acquired the lease
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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