Norris O. and Betty J. Whitley - Page 2

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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.                                                            
               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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