Glynn v. Commissioner
United States Tax Court
Petitioner, the Superintendent of Schools of Foxborough, Mass., was requested to resign by the school committee since the committee did not agree with the way petitioner was managing the school system. Petitioner threatened legal action based upon a series of charges leveled by him against the committee, none of which alleged that petitioner suffered personal injuries or sickness, but did allege damage to petitioner's professional reputation.
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Petitioner, the Superintendent of Schools of Foxborough, Mass., was requested to resign by the school committee since the committee did not agree with the way petitioner was managing the school system. Petitioner threatened legal action based upon a series of charges leveled by him against the committee, none of which alleged that petitioner suffered personal injuries or sickness, but did allege damage to petitioner's professional reputation. The dispute was settled by payment of a lump-sum amount to petitioner, described in the settlement agreement as being "in lieu of doctoral advantages."…
1Opinion of the Court
Nims, Judge:
Respondent determined a deficiency of $12,268.89 in petitioners’ Federal income tax for the year 1973. After concessions by petitioners, the issues remaining for decision are: (1) Whether a $25,000 payment to petitioner from the Town of Foxborough, Mass., in settlement of threatened litigation, is excludable from gross income; and (2) whether petitioners properly excluded $6,400 in wages from gross income.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by reference.
At the time the petition was filed,…
2Cases cited5 opinions
- Mason K. Knuckles and Bernice A. Knuckles v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1965
- Seay v. CommissionerUnited States Tax Court · 1972
- Nathan Agar and Christina Edith Agar v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Hawkins v. CommissionerUnited States Board of Tax Appeals · 1927
- United States v. Dorothy R. GarberCourt of Appeals for the Fifth Circuit · 1979
3Cited by69 opinions
- Threlkeld v. CommissionerUnited States Tax Court · 1986
- Frank E. & Mildred E. Rickel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
- Metzger v. CommissionerUnited States Tax Court · 1987
- Skripak v. CommissionerUnited States Tax Court · 1985
- Bent v. CommissionerUnited States Tax Court · 1986
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