- 12 - whether an LPCF payment under Louisiana law included interest which was not excludable from income under section 104(a)(2). As in Greer, the reasoning of Rozpad is helpful in deciding this issue. Petitioners contend that Greer is distinguishable because the Agreement and the Satisfaction of Judgment in that case did not state that the settlement was entirely for personal injuries. We disagree. The RRC agreement is similar to the Agreement and the Satisfaction of Judgment in Greer because the agreement in each case was silent as to whether any part of the settlement was for interest. The check from LPCF to the taxpayer in Greer bore a numerical code which indicated that part of the payment was for interest. Here, the LPCF check to petitioners also bore a numerical code which indicated $439,000 of the payment was for interest. D. Conclusion We conclude that $255,983 of the $893,000 payment was interest. To reflect respondent’s concession and the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011