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CLARK v. COMMISSIONER

Docket No. 27983-91.

67 T.C.M. 3105 (1994)

T.C. Memo. 1994-278

Deveaux and Marjorie Clark v. Commissioner.

United States Tax Court.

Filed June 16, 1994.

Attorney(s) appearing for the Case

Belan K. Wagner, Carl P. Blaine, 1792 Tribute Rd., Sacramento, Calif., and Jeffrey W. Curcio, 300 Capitol Mall, P.O. Box 3034, Sacramento, Calif., for the petitioner. Kathryn K. Vetter, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1986 in the amount of $129,443 and an addition to tax under section 6661 in the amount of $32,361.

The issues for decision are: (1) Whether the amount of $497,164 received in 1986 by petitioner Deveaux Clark upon the termination of his agency management contract with Farmers Insurance Group is taxable as ordinary income or...

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