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 taxedPage: 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007