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ESTATE OF WRIGHT v. COMMISSIONER

Dkt. No. 173-97.

94 T.C.M. 295 (2007)

T.C. Memo. 2007-278

Estate of Charles Whittaker Wright, Deceased, Valerie Wright-Ballin, Administratrix, and Betty J. Wright, Deceased v. Commissioner.

United States Tax Court.

September 13, 2007.

Attorney(s) appearing for the Case

Gary H. Kuwada and Steve Mather, for petitioners.

Wesley J. Wong, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Respondent determined a deficiency in income tax of $413,369 against petitioners for the tax year 1992, based on respondent's position that Charles Whitaker Wright and Betty J. Wright (hereinafter petitioners) erroneously excluded from gross income settlement proceeds of $1,269,950 pursuant to section 104(a)(2).1 We find that respondent's determination was in error regarding...

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