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STEVAN v. COMMISSIONER

Docket No. 4311-99.

80 T.C.M. 420 (2000)

T.C. Memo. 2000-302

David Stevan and Karen Ann Brandriet v. Commissioner.

United States Tax Court.

Filed September 25, 2000.

Attorney(s) appearing for the Case

David Stevan Brandriet and Karen Ann Brandriet, pro sese. Melissa J. Hedtke, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined a $75,739 deficiency in petitioners' Federal income tax for the 1993 taxable year.

After concessions,1 the issues for decision are: (1) Whether a punitive damage award of $200,000 that petitioners received in 1993 is includable in their gross income. We hold it is.2 (2) Whether petitioners are entitled to deduct interest...

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