Cliff Connors - Page 2

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               After concessions by the parties, the issues for decision              
               (1) Whether payments made to petitioner, pursuant to a long-           
          term disability income settlement, by Connecticut General Life              
          Insurance Co. (Connecticut General) are taxable gross income to             
          petitioner in 2002;                                                         
               (2) whether Citibank interest income of $972, attributable             
          to the Quadrino & Schwartz, P.C. (Quadrino & Schwartz), escrow              
          account, and $15 of interest income from a U.S. savings bond are            
          taxable to petitioner in 2002;                                              
               (3) whether petitioner is entitled to certain credits,                 
          exemptions, or deductions in 2002;                                          
               (4) whether petitioner is liable for the additions to tax              
          under section 6651(a)(1) and (2); and                                       
               (5) whether petitioner’s proper filing status for 2002 is              
          married filing separately.                                                  
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   

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