T.C. Memo. 2003-82
UNITED STATES TAX COURT
RALPH W. EMERSON AND SUZANNE O. EMERSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5877-00. Filed March 20, 2003.
Thomas Casazza, for petitioners.
Margaret A. Martin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $34,956
in petitioners’ Federal income tax for 1998 and a penalty of
$6,991.20 under section 6662(a). The issues for decision are:
(1) Whether $90,684 petitioners received from settlement of a
lawsuit is excludable from income under section 104(a)(2);
(2) whether the settlement amount is subject to self-employment
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