- 2 - I.R.C., or for medical care attributable to emotional distress as required by the flush language of sec. 104(a), I.R.C. Hans I. Lindberg, for petitioner. Gerald L. Brantley, for respondent. MEMORANDUM OPINION WHERRY, Judge: Respondent determined a Federal income tax deficiency for petitioner’s 1998 taxable year of $157,357. Respondent also determined an accuracy-related penalty under section 6662(a) of $31,471 for 1998. After concessions, the issue for decision is whether damages petitioner received in satisfaction of a lawsuit judgment are includable in her gross income for 1998. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background This case was submitted fully stipulated pursuant to Rule 122. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. At the time the petition was filed in this case, petitioner resided in The Woodlands, Texas.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011