P & X Markets, Inc. v. Commissioner

106 T.C. No. 26

UNITED STATES TAX COURT P & X MARKETS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15836-95. Filed June 13, 1996. P, a corporation, filed a lawsuit against various defendants alleging breach of contract, malicious prosecution, intentional interference with business relationship, fraud, and violation of fiduciary and statutory duties. P received $850,000 to settle the suit, and it paid $198,367 in legal fees in connection therewith. On its Federal income tax return, P included $83,608 of the settlement proceeds in its gross income. P relied on…