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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.
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