John L. Sullivan - Page 2




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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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