Jesse and Tawara Goode - Page 2

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               P-H received any part of the $135,000 sum on account of                
               personal physical injury or physical sickness, as                      
               required by sec. 104(a)(2), I.R.C.                                     
                    Held, further, Ps are liable for accuracy-related                 
               penalties pursuant to sec. 6662, I.R.C.                                
                    Held, further, Jurisdiction of this Court is not                  
               available to consider Ps claim for suspension of                       
               interest under sec. 6404(g), I.R.C.                                    



               Thomas F. DeCaro, Jr., for petitioners.                                
               Innessa Glazman Molot, for respondent.                                 


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               NIMS, Judge:  Respondent determined a deficiency of $146,316           
          in petitioners’ 2001 Federal income tax, as well as an accuracy-            
          related penalty under section 6662(a) and (d) of $29,263 for                
          substantial understatement of income tax.  Unless otherwise                 
          indicated, all section references are to the Internal Revenue               
          Code in effect for the year in issue.   After concessions, the              
          issues for decision are: (1) Whether any portion or the entirety            
          of certain unreported settlement proceeds aggregating $135,000,             
          specifically identified in a settlement agreement between                   
          petitioner Jesse Goode and the District of Columbia as nontaxable           
          pursuant to section 104(a)(2), is excludable from petitioners’              
          2001 gross income; (2) whether petitioners are liable for                   







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