Legal Opinion

Metzger v. Commissioner

United States Tax Court

Decided April 9, 1987No. Docket No. 6510-78PublishedCited by 96 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Wilson v. GarciaSupreme Court of the United States · 1985
  3. Carey v. PiphusSupreme Court of the United States · 1978
  4. Johnson v. Railway Express Agency, Inc.Supreme Court of the United States · 1975
  5. Runyon v. McCrarySupreme Court of the United States · 1976

22 more not listed; retrieve them via the Exa API.

3Cited by96 opinions

  1. Carl Johnston v. Harris County Flood Control DistrictCourt of Appeals for the Fifth Circuit · 1989
  2. James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
  3. Robinson v. CommissionerUnited States Tax Court · 1994
  4. Frank E. & Mildred E. Rickel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
  5. Bagley v. CommissionerUnited States Tax Court · 1995

91 more not listed; retrieve them via the Exa API.

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