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(2) If not so barred, then whether:
(a) Petitioner is collaterally estopped by the
order from asserting that the amount of compensation he
received in 1994 is excludable from gross income under
section 104(a)(2).
(b) The discharge of indebtedness income
petitioner received in 1994 is excludable from gross
income under section 108(a)(1)(B).
(c) The income petitioner realized from the sale
of stock in 1994 should be taxed at capital gains
rates.
(d) Respondent erroneously calculated the amount
of disability insurance benefits petitioner received in
1994.
(e) Respondent erroneously included loan proceeds
in petitioner’s gross income for 1994.
(3) Whether petitioner is entitled to the filing
status of married filing jointly.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this
reference.
Petitioner resided in Sterling, Virginia, when he filed the
petition in the instant case.
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