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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.
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