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NORMAN C. v. COMMISSIONER

Dkt. No. 16753-05.

94 T.C.M. 303 (2007)

T.C. Memo. 2007-282

Norman C. and Rosemary J. Eckersley v. Commissioner.

United States Tax Court.

September 18, 2007.

Attorney(s) appearing for the Case

Arthur V. Pearson, for petitioners.

John W. Strate, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court to redetermine respondent's determination of a $153,978 deficiency in petitioners' 1999 Federal income tax. We decide whether the proceeds that petitioners received for settlement of a claim to ownership of a life insurance policy are taxable as ordinary income or as a capital gain. We hold that the proceeds are taxed as...

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