Yancy D. Greer and Rita K. Greer - Page 7




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          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, the                






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