McKay v. Commissioner
United States Tax Court
P was an officer of A. A terminated P's employment. P filed a lawsuit in Federal District Court against A for wrongful discharge, breach of employment contract, RICO violations, and punitive damages. The jury awarded P lost compensation in the amount of $ 1,602,103 and future damages of $ 12,846,209 that were trebled for A's violation of RICO. The jury also awarded P a total of $ 1,250,000 in punitive damages.
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P was an officer of A. A terminated P's employment. P filed a lawsuit in Federal District Court against A for wrongful discharge, breach of employment contract, RICO violations, and punitive damages. The jury awarded P lost compensation in the amount of $ 1,602,103 and future damages of $ 12,846,209 that were trebled for A's violation of RICO. The jury also awarded P a total of $ 1,250,000 in punitive damages. After the award and final judgment were entered, the parties negotiated a settlement agreement under which A paid P $ 16,744,300 in extinguishment of P's claims. The agreement further…
1Opinion of the Court
Wells, Judge:
Respondent determined the following deficiencies in and additions to petitioners’ Federal income taxes:
Additions to tax Year Deficiency sec. 6651(a)(1)
-0-1983 $14,588
$2,297 1984 22,340
7,039 1985 29,156
7,375 1986 30,527
1988 3,571,867 o
1989 101,636 o
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions,2 the issues we are asked to decide relate to the settlement of claims petitioner Bill McKay (hereinafter petitioner) made…
2Cases cited37 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- United States v. GilmoreSupreme Court of the United States · 1963
- United States v. BurkeSupreme Court of the United States · 1992
- United States v. SullivanSupreme Court of the United States · 1927
- Primuth v. CommissionerUnited States Tax Court · 1970
32 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Hughes A. Bagley and Marilyn B. Bagley v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1997
- Bagley v. CommissionerUnited States Tax Court · 1995
- Alexander v. Internal Revenue Service of the United StatesCourt of Appeals for the First Circuit · 1995
- Charles Francisco Cecilia Francisco v. United StatesCourt of Appeals for the Third Circuit · 2001
- Alexander v. CommissionerUnited States Tax Court · 1995
22 more not listed; retrieve them via the Exa API.