T.C. Memo. 2007-282
UNITED STATES TAX COURT
NORMAN C. AND ROSEMARY J. ECKERSLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16753-05. Filed September 18, 2007.
Arthur V. Pearson, for petitioners.
John W. Strate, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine respondent’s determination of a $153,978 deficiency
in petitioners’ 1999 Federal income tax. We decide whether the
proceeds that petitioners received for settlement of a claim to
ownership of a life insurance policy are taxable as ordinary
income or as a capital gain. We hold that the proceeds are taxed
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Last modified: November 10, 2007