-15-
settlement amounts were not paid “on account of personal physical
injuries or sickness,” Commissioner v. Schleier, 515 U.S. at 337,
and are not excludable from gross income under section 104(a)(2).
Conclusion
Respondent’s determination that the settlement payment is
includable in petitioners’ income for 2002 is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011