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COBLENZ v. COMMISSIONER

Docket No. 22383-97.

79 T.C.M. 1881 (2000)

T.C. Memo. 2000-131

Madeline A. Coblenz and William J. Mason v. Commissioner.

United States Tax Court.

Filed April 11, 2000.

Attorney(s) appearing for the Case

William A. Roberts, for the petitioners. Wanda M. Cohen and Russell S. Shieldes (specially recognized), for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

For 1995, respondent determined a deficiency of $88,497 in and an accuracy-related penalty of $17,699 on petitioners' Federal income tax. The issues for decision are (1) whether $266,6861 received by William J. Mason (hereinafter, petitioner) in connection with a settlement of a lawsuit should be excluded from gross income pursuant to section 104(a)(2); and (2) whether petitioners...

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