MEMORANDUM OPINION
COLVIN, Judge:
Respondent determined that petitioner had a $12,024 deficiency in income tax for 1990. The sole issue for decision is whether part of the $137,437.50 petitioner received in settlement of a tort action is prejudgment interest, and, if so, whether it is excludable from gross income as damages for a personal injury under section 104(a)(2). We hold that $64,510.60 (45.43 percent of the $137,437.50 payment) was prejudgment interest...
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