Steven P. and Maureen Cade, (1999)

Extract

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Steven P. and Maureen Cade, (1999)

T.C. Memo. 1999-394

UNITED STATES TAX COURT STEVEN P. AND MAUREEN CADE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22819-97. Filed December 3, 1999.

Charles W. Becker, for petitioners. Thomas A. Dombrowski, for respondent.

MEMORANDUM OPINION LARO, Judge: This case is before the Court fully stipulated. See Rule 122. Respondent determined a $646,800 deficiency in petitioners' 1993 Federal income tax. Respondent later asserted in his amended answer that the deficiency was $651,000.

We must decide whether section 104(a)(2) allows petitioners to exclude from their gross income certain proceeds received in settlement of a lawsuit. We hold it does not. Unless otherwise indicated, section references are to the Internal Revenue Code applicable to 1993, and Rule references are to the Tax Court Rules of Practice and Procedure. The term 'petitioner' refers to Steven P. Cade.

Background All facts have been stipulated. The sti...

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