- 3 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011