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James Richard Cox, for petitioners.
Jeanne Gramling, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court fully
stipulated. See Rule 122. Norris O. and Betty J. Whitley
petitioned the Court to redetermine deficiencies of $75,694 and
$263 in their 1992 and 1993 Federal income tax, respectively.
Following petitioners' concessions, we must decide whether their
1992 gross income includes $250,000 in punitive damages that they
received during 1992. We hold it does. Unless otherwise
indicated, section references are to the Internal Revenue Code in
effect for 1992. Rule references are to the Tax Court Rules of
Practice and Procedure. Although Betty J. Whitley is a
copetitioner, we hereinafter refer to Norris O. Whitley as the
sole petitioner.
Background
All facts have been stipulated and are so found. The
stipulation of facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner and Betty J.
Whitley are husband and wife. They filed joint 1992 and 1993
Federal income tax returns. They resided in Sumter, South
Carolina, when they petitioned the Court.
Petitioner began working as an agent for Academy Life
Insurance Company (Academy) in the late 1970's. He worked for it
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