Charles E. and Noel K. Bradley - Page 43

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          conjure an amount to settle alleged tort-like personal injury               
          claims.  Absent proof of a specific payment for tort-like                   
          personal injuries or evidence that Ormet intended its $12 million           
          payment for Mr. Bradley’s personal injuries as part of a bona               
          fide dispute settlement, petitioners do not meet the criteria for           
          exclusion of the $12 million from income under section 104(a)(2).           
          Thus, in accordance with section 61, the $12 million payment must           
          be included in petitioners’ gross income for the 1995 taxable               
          year.                                                                       
               To reflect the foregoing and concessions made by the                   
          parties,                                                                    


                                                  Decision will be entered            
                                             under Rule 155.                          






















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Last modified: May 25, 2011