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We find that the settlement payment is not excludable from
petitioners’ 1999 income under the provisions of section
104(a)(2), and petitioners’ claim for a refund is denied.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing, and to ensure that any agreements
between the parties are properly taken into account,
Petitioners’ claim for refund
is denied, and decision will be
entered under Rule 155.
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Last modified: May 25, 2011