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STEPHEN G. v. COMMISSIONER

Docket No. 6523-02.

85 T.C.M. 1489 (2003)

T.C. Memo. 2003-173

Stephen G. and Karen P. Shaltz v. Commissioner.

United States Tax Court.

Filed June 11, 2003.

Attorney(s) appearing for the Case

Robert J. Zinkel, Jr., for the petitioners.

John W. Stevens, for the respondent.

MEMORANDUM OPINION

LARO, Judge.

This case is before the Court for decision without trial. See Rule 122. Respondent determined a deficiency of $12,205 in petitioners' 1999 Federal income tax and a related accuracy-related penalty of $2,441 under section 6662(a). Following concessions by respondent, we are left to decide whether section 104(a)(2) allows petitioners to exclude from their gross income a payment that Karen P. Shaltz (petitioner) received from...

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