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NAGOURNEY v. COMMISSIONER

Docket No. 12771-86.

57 T.C.M. 954 (1989)

T.C. Memo. 1989-339

Edward I. Nagourney and Louise P. Nagourney v. Commissioner.

United States Tax Court.

Filed July 17, 1989.

Attorney(s) appearing for the Case

Thomas R. Frantz, One Columbus Center, Virginia Beach, Va., for the petitioners. Richard F. Stein, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a $140,161 deficiency in petitioners' 1983 Federal income tax. The issue for our decision is whether receipt of a $275,000 cash payment and an automobile valued at $12,735 were damages received on account of personal injuries and, thus, excludible from petitioners' gross income under section 104(a)(2).1

Findings of Fact

Some of the facts...

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