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ALLUM v. COMMISSIONER

Docket No. 2424-03.

90 T.C.M. 74 (2005)

T.C. Memo. 2005-177

Robert L. Allum v. Commissioner.

United States Tax Court.

July 20, 2005.

Attorney(s) appearing for the Case

Robert L. Allum, pro se.

Richard D. D'Estrada, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency of $185,491 in petitioner's Federal income tax for 1999. The issues for decision1 are: (1) Whether settlement proceeds petitioner received may be excluded from his gross income under section 104(a)(2);2 and (2) if the total settlement proceeds are not excluded under section 104(a)(2), whether a portion of the...

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