- 7 - as compensation for her personal injuries and should be excluded from gross income under section 104(a)(2). Petitioners contend that any intimation of interest from the checks or otherwise reflects only internal bookkeeping utilized by the Doctor's Insurance and the State's Insurance. On February 5, and 8, 1993, approximately 2 weeks after the January 19, 1993, court judgment was entered, the Doctor's Insurance and the State's Insurance issued to petitioner the four checks. With regard to the three checks issued to petitioner by the Doctor's Insurance, according to testimony at trial and correspondence in evidence, the $100,000 check constitutes the $100,000 limit of liability on damages under Louisiana law, the $7,473 check constitutes court costs, and the $17,930 check constitutes interest. We conclude that the check for $17,930 constitutes interest. With regard to the $195,477 check issued to petitioner by the State's Insurance, the numerical code and other evidence at trial establish that $125,477 thereof constitutes interest. We so hold. Petitioners' argument that a separate settlement existed between petitioner, the Doctor's Insurance, and the State's Insurance disparate from the court judgment entered in petitioner's favor is not supported by the evidence. The three checks received from the Doctor's Insurance total $125,403, thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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