Glenshaw Glass Co. v. Commissioner
United States Tax Court
1. Where a lump sum of money is received in settlement of various claims, an allocation of specific amounts to each of the several claims is necessary and proper. 2. Sums received in settlement of punitive damages do not constitute taxable income. 3. Sums received in settlement of claims for anticipated profits are taxable as ordinary income.
1Opinion of the Court
OPINION.
Arundell, Judge:
The basic issue before us is the taxability of a sum of money received by the petitioner in 1947 in compromise settlement of several claims asserted against Hartford-Empire Company (hereinafter referred to as Hartford) in two suits and in subsequent settlement negotiations. The claims were for: (1) reimbursement of the sum paid in settlement of the accounting order; (2) reimbursement of litigation and travel expenses; (3) reimbursement of loss incurred in dismantling Shawkee feeders; (4) reimbursement of royalties paid to Hartford; (5) interest on refund of royalties…
2Cases cited14 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Helvering v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1942
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- H. Liebes & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
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3Cited by2 opinions
- Commissioner of Internal Revenue v. Obear-Nester Glass CompanyCourt of Appeals for the Seventh Circuit · 1954
- Glenshaw Glass Co. v. CommissionerUnited States Tax Court · 1952