- 14 - 104(a)(2) does not exclude damages which are “received pursuant to the settlement of economic rights arising out of a contract (e.g., lost profits)”); Gregg v. Commissioner, T.C. Memo. 1999- 10; Kightlinger v. Commissioner, T.C. Memo. 1998-357. We hold that section 104(a)(2) does not operate to exclude from petitioner’s gross income any of the $2,315,000 at issue. As to the $10,000 in dispute, petitioner was paid that amount by virtue of the fact that the jury had concluded that his personal property had been converted by CGC and the Heller Group. Petitioner was paid the $10,000 as a compensation for property damage and not on account of a personal injury. We conclude and hold that the $10,000 is not excluded from petitioner’s gross income by virtue of section 104(a)(2). We have considered all of the parties’ arguments and, to the extent not discussed above, find them to be without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011