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CLARK v. COMMISSIONER

Docket No. 7144-96.

73 T.C.M. 2466 (1997)

T.C. Memo. 1997-156

Deborah E. Clark v. Commissioner.

United States Tax Court.

Filed March 31, 1997.

Attorney(s) appearing for the Case

Deborah E. Clark, pro se. John E. Budde, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency in petitioner's 1992 Federal income tax of $72,449 and an addition to tax pursuant to section 6651(a)(1)1 in the amount of $2.

After concessions, the sole issue remaining for decision is whether petitioner is entitled to exclude, pursuant to section 104(a)(2), $283,394.56 of settlement proceeds received from State Farm Insurance (State...

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