T.C. Memo. 2005-223
UNITED STATES TAX COURT
CHARLES E. AND NOEL K. BRADLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19074-02. Filed September 26, 2005.
Ps excluded $12 million of a $76 million
settlement from gross income for the 1995 taxable year
pursuant to sec. 104 (a)(2), I.R.C. R determined the
$12 million was not excludable.
Held: Ps are not entitled to exclude the $12
million settlement amount from gross income.
Charles E. and Noel K. Bradley, pro sese.
Robert E. Marum, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined a deficiency in
petitioners’ Federal income tax for the 1995 taxable year in the
amount of $4,676,578 and a penalty pursuant to section 6662(a) in
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