Metzger v. Commissioner
United States Tax Court
Petitioner, an associate professor at college M, was not recommended for a tenured position at M; thus, her teaching position at M terminated on expiration of her employment contract.
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Petitioner, an associate professor at college M, was not recommended for a tenured position at M; thus, her teaching position at M terminated on expiration of her employment contract. Petitioner brought four proceedings against M and certain college officials in various State and Federal forums, alleging that M's decision to deny her tenure constituted a breach of contract and a violation of her constitutional and statutory rights to be free from discrimination on account of sex and national origin. She asked for awards of back pay, reinstatement, a grant of tenure, damages, and declaratory…
1Opinion of the Court
CHABOT, Judge:
Respondent determined a deficiency in Federal individual income tax against petitioner for 1975 in the amount of $1,745. By amendment to answer, respondent asserts an increased deficiency in the amount of $18,196.28, for a total deficiency in the amount of $19,941.28.
The issues for decision are as follows:(1) Whether one-half of the $75,000 payment to petitioner from Muhlenberg College in settlement of litigation is excludable from gross income1 under section 104(a)(2);2(2) Whether petitioner is entitled to deduct all of the amount she paid as a legal fee if a portion of the…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Wilson v. GarciaSupreme Court of the United States · 1985
- Carey v. PiphusSupreme Court of the United States · 1978
- Johnson v. Railway Express Agency, Inc.Supreme Court of the United States · 1975
- Runyon v. McCrarySupreme Court of the United States · 1976
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3Cited by96 opinions
- Carl Johnston v. Harris County Flood Control DistrictCourt of Appeals for the Fifth Circuit · 1989
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Robinson v. CommissionerUnited States Tax Court · 1994
- Frank E. & Mildred E. Rickel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
- Bagley v. CommissionerUnited States Tax Court · 1995
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