- 2 - petitioner is not liable for the addition to tax under either section 6651(a) or 6654. Following other concessions, the issues for decision are: (1) Whether interest received as part of a personal injury award is includable in petitioner's gross income for 1989; and if so, (2) the amount of interest allocable to petitioner; and (3) the amount of the Schedule A deduction for legal fees incurred in receiving the interest. All section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background This case was submitted fully stipulated under Rule 122. The stipulations of facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioner resided in Warwick, Rhode Island, at the time he filed his petition in this case. Petitioner computed his income and expenses under the cash receipts and expenditures method of accounting. Petitioner (hereinafter sometimes referred to as Mr. Sullivan) and Becky Lusignan (Mrs. Sullivan) were married on March 5, 1977; they had three children. Mr. and Mrs. Sullivan were divorced on August 8, 1990.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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