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DELANEY v. COMMISSIONER

Docket No. 3387-94.

70 T.C.M. 353 (1995)

T.C. Memo. 1995-378

Joseph J. Delaney and Jane H. Delaney v. Commissioner.

United States Tax Court.

Filed August 8, 1995.

Attorney(s) appearing for the Case

Justin S. Holden, Providence, R.I., for the petitioners. Carmino J. Santaniello and Bradford A. Johnson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1991 in the amount of $20,580.

The issues to be decided are: (1) Whether a portion of certain proceeds received by Joseph J. Delaney (petitioner) in settlement of a tort action is excludable from gross income under section 104(a)(2)1 as...

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