Legal Opinion
Herrmann v. United States
United States Court of Federal Claims
Decided June 21, 2017No. 14-941TPublished
1Opinion of the Court
Post-trial decision in a tax refund case; timing of receipt of income; formulaic bonus paid to an American member of an English limited liability partnership in her capacity other than as a member; I.R.C. § 707(a)(2)(A)
ORDER 1
LETTOW, Judge.
This post-trial opinion addresses a refund claim that turns on the timing of income received and taxes due on an $18,748,838 payment (“$1S million payment”) to plaintiff Mina Gerowin Herrmann by her then-employer, Paulson Europe LLP (“PELLP”), based in London. PELLP ordered the payment to be issued on December 31, 2008, but Ms. Herrmann did not receive it…
2Cases cited13 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Lewis Et Al. v. Reynolds, Collector of Internal RevenueSupreme Court of the United States · 1932
- Cook v. United StatesUnited States Court of Federal Claims · 2000
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