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CAREY v. COMMISSIONER

Docket No. 1670-96.

74 T.C.M. 705 (1997)

T.C. Memo. 1997-434

Allen L. and Diane A. Carey v. Commissioner.

United States Tax Court.

Filed September 23, 1997.

Attorney(s) appearing for the Case

Allen L. and Diane A. Carey, pro se. Howard P. Levine, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $27,901 for the taxable year 1993.

This case is before us on respondent's motion for summary judgment under Rule 121.1 The issue for decision is whether petitioners may exclude from gross income, under section 104(a)(2), amounts received from petitioner...

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