- 43 - 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43
Last modified: May 25, 2011