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clearly based on a physical injury under section 104(a)(2), and
the settlement was not received in lieu of the prosecution of a
physical tort or a tort type injury.
Accordingly, the settlement received is not excludable from
gross income under section 104(a)(2).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011