T.C. Memo. 2007-278
UNITED STATES TAX COURT
ESTATE OF CHARLES WHITTAKER WRIGHT, DECEASED,
VALERIE WRIGHT-BALLIN, ADMINISTRATRIX, AND BETTY J. WRIGHT,
DECEASED, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 173-97. Filed September 13, 2007.
Gary H. Kuwada and Steve Mather, for petitioners.
Wesley J. Wong, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Respondent determined a deficiency in income
tax of $413,369 against petitioners for the tax year 1992, based
on respondent’s position that Charles Whitaker Wright and Betty
J. Wright (hereinafter petitioners) erroneously excluded from
gross income settlement proceeds of $1,269,950 pursuant to
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Last modified: November 10, 2007