Dall v. Commissioner

OPINION.

Rice, Judge:

Petitioner concedes that the entire amount which he received pursuant to the settlement of his suit against Tennessee and certain of its directors was taxable income. He contends, however, that he is entitled to report such amount under the provisions of section 107 (a) of the 1939 Code.

The respondent argues that the petitioner has failed to bring himself 'within the specific requirements of that section. It is apparent from our findings of fact herein that the petitioner has so failed.

The essential fact which the petitioner has not established is that stock having a fair…