T.C. Memo. 2002-5
UNITED STATES TAX COURT
SIGITAS J. BANAITIS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4323-00. Filed January 8, 2002.
Joseph Wetzel and Michael C. Wetzel, for petitioner.
Shirley M. Francis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $1,708,216
deficiency in income tax for petitioner’s 1995 taxable year. The
issues for our consideration are: (1) Whether petitioner is
entitled to exclude damages received in settlement of a lawsuit
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