Norman C. and Rosemary J. Eckersley - Page 1

                                 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