Quantum Company Trust - Page 3




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          whether proceeds from the settlement of a lawsuit arising out of            
          Mr. Norton’s fishing activities are excludable from income pursuant         
          to section 104(a)(2); (3) whether statutory prejudgment interest            
          the Nortons received in connection with a personal injury award is          
          excludable  from income pursuant to section 104(a)(2); (4) whether          
          the Nortons are entitled to a $15,000 deduction for an ostensible           
          payment of  environmental cleanup expenses made in connection with          
          their acquisition of rental property; and (5) whether the Nortons           
          are liable for the accuracy-related penalty.                                
               All section references are to the Internal Revenue Code as in          
          effect for the year under consideration.  All Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
          Background                                                                  
               The Nortons, husband and wife, resided in Palmer, Alaska, at           
          the time they filed their petition.  Quantum Co. Trust’s mailing            
          address at the time the trustee thereof filed a petition was                
          Palmer, Alaska.                                                             
               During 1993, Mr. Norton was engaged in two unrelated business          
          activities–-construction of residential and commercial buildings            
          (through Northridge) and commercial fishing.  Northridge operated           
          as a general contractor with respect to the construction of                 






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Last modified: May 25, 2011