United States Tax Court April 10, 1972, Docket No. 2906-70 (Seay v. Commissioner)

lead-opinion

Simpson, Judge:

The respondent determined a deficiency of $26,066.60 in the petitioners’ 1966 Federal income tax. The only issue for decision is whether $45,000 of a $105,000 payment, which one of the petitioners received in settlement of claims against his former employer, is excludable from gross income as damages received on account of personal injuries.

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