Robinson v. Commissioner
United States Tax Court
Ps filed a lawsuit against bank (B) alleging that B failed improperly to release its lien on Ps' property. Following a jury verdict for Ps totaling approximately $ 60 million, which included $ 6 million for lost profits, $ 1.5 million for mental anguish, and $ 50 million for punitive damages, Ps and B agreed to settle the lawsuit for $ 10,691,972.43. In connection with their settlement, Ps prepared unilaterally a final judgment allocating 95 percent of the settlement…
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Ps filed a lawsuit against bank (B) alleging that B failed improperly to release its lien on Ps' property. Following a jury verdict for Ps totaling approximately $ 60 million, which included $ 6 million for lost profits, $ 1.5 million for mental anguish, and $ 50 million for punitive damages, Ps and B agreed to settle the lawsuit for $ 10,691,972.43. In connection with their settlement, Ps prepared unilaterally a final judgment allocating 95 percent of the settlement proceeds to tortlike personal injuries; the final judgment was entered by the trial court in accordance with the settlement.…
1Opinion of the Court
Laro, Judge:
This case is before the Court pursuant to a petition filed by Edward E. Robinson and Sandra Robinson (petitioners) for a redetermination of respondent’s determination reflected in her notice of deficiency issued to them on July 25, 1991. Respondent’s notice of deficiency reflected her determination of deficiencies in petitioners’ 1987 and 1988 Federal income taxes equal to $1,579,549 and $90,800, respectively.
A trial was held on this matter on February 23, 1993, in Houston, Texas. At the conclusion of the trial, the Court allowed respondent to amend her answer to conform to the…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- United States v. BurkeSupreme Court of the United States · 1992
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
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3Cited by101 opinions
- Bagley v. CommissionerUnited States Tax Court · 1995
- Delaney v. CommissionerCourt of Appeals for the First Circuit · 1996
- Srivastava v. CommissionerCourt of Appeals for the Fifth Circuit · 2000
- Charles Francisco Cecilia Francisco v. United StatesCourt of Appeals for the Third Circuit · 2001
- McKay v. CommissionerUnited States Tax Court · 1994
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