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of personal injuries within the meaning of section 104(a)(2).
Accordingly, we sustain respondent’s determination on this issue.
B. Prejudgment Interest
Petitioners contend that the prejudgment interest they
received is excludable under section 104(a)(2) as damages
received on account of personal injuries. As petitioners
acknowledge, however, the well-established precedents in this
Court hold that prejudgment interest is taxable even when
attributable to damages excludable under section 104(a)(2). See,
e.g., Bagley v. Commissioner, 105 T.C. 396, 419-420 (1995);
Kovacs v. Commissioner, 100 T.C. 124, 129-139 (1993), affd.
without published opinion 25 F.3d. 1048 (6th Cir. 1994); Rozpad
v. Commissioner, T.C. Memo. 1997-528, affd. 154 F.3d 1 (1st Cir.
1998).
Having concluded that petitioner’s damages were not received
on account of personal injuries within the meaning of section
104(a)(2), a fortiori we conclude that petitioner’s prejudgment
interest was not attributable to personal injuries, and we
decline petitioners’ invitation to disturb the well-established
precedents of this Court.
C. Evidentiary Issues
In the parties’ stipulation of facts, respondent reserved
certain evidentiary objections that we now address.
Paragraph Nos. 25 and 26 of the stipulation of facts relate
to the nature of petitioner's business acumen and personal
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