T.C. Memo. 2002-29
UNITED STATES TAX COURT
ORIN F. FARNSWORTH AND MARY L. FARNSWORTH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14460-99. Filed January 28, 2002.
Orin F. Farnsworth and Mary L. Farnsworth, pro sese.
Paul K. Webb, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined a deficiency of
$111,808 in petitioners’ joint Federal income tax for 1995.
After concessions by the parties, there are two issues for
decision: (1) Whether petitioners are entitled to exclude from
income, as a recovery of basis, any portion of the “contract
value” termination payments received in 1995 by petitioner Orin
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