SCOTT, Judge: Respondent determined a deficiency in petitioners’ income tax for the calendar year 1987 in the amount of $488,976.31. The issues for decision are: (1) What portion, if any, of the amount of $1.5 million paid to Hughes Bagley (petitioner) in settlement of a suit against Iowa Beef Processors, Inc. (IBP), is allocable to punitive damages; (2) whether the $500,000 in punitive damag…
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