T.C. Memo. 2003-36 UNITED STATES TAX COURT CHRISTOPHER J. AND VICKILYNN M. MCCANN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 370-01. Filed February 14, 2003. A. Albert Ajubita and Wanda L. Theriot, for petitioners. Susan S. Canavello, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined an $83,922 deficiency in petitioners’ Federal income tax for 1994. Petitioners received $839,000 in 1994 in settlement of a medical malpractice lawsuit. Respondent concedes that $583,017 of that amount is excludable under section 104(a)(2). The sole issue for decision is whether the remaining $255,983 is alsoPage: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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