T.C. Memo. 2000-302
UNITED STATES TAX COURT
DAVID STEVAN AND KAREN ANN BRANDRIET, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4311-99. Filed September 25, 2000.
David Stevan Brandriet and Karen Ann Brandriet, pro sese.
Melissa J. Hedtke, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined a $75,739 deficiency in
petitioners' Federal income tax for the 1993 taxable year.
After concessions,1 the issues for decision are: (1)
1Respondent concedes that the compensatory damage award of
$41,453.22 that petitioners received in 1993 is excluded from
petitioners' gross income pursuant to sec. 104(a)(2).
Respondent also concedes that petitioners' business, Malligan's
(continued...)
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