Legal Opinion

Bagley v. Commissioner

United States Tax Court

Decided December 11, 1995No. Docket No. 531-93PublishedCited by 72 opinions

In 1987, P received $ 150,000 in compensatory damages and $ 500,000 in punitive damages pursuant to judgment on a claim for tortious interference with future employment, with statutory interest thereon, and $ 1.5 million in settlement of claims for tortious interference with future employment, libel, and invasion of privacy. P excluded all of these amounts from income under sec. 104(a)(2), I.R.C.

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In 1987, P received $ 150,000 in compensatory damages and $ 500,000 in punitive damages pursuant to judgment on a claim for tortious interference with future employment, with statutory interest thereon, and $ 1.5 million in settlement of claims for tortious interference with future employment, libel, and invasion of privacy. P excluded all of these amounts from income under sec. 104(a)(2), I.R.C. R determined that the punitive damages and interest received from the judgment and $ 1.305 million of the settlement amount attributable to punitive damages were not excludable under sec. 104(a)(2),…

1Opinion of the Court

SCOTT, Judge:

Respondent determined a deficiency in petitioners’ income tax for the calendar year 1987 in the amount of $488,976.31. The issues for decision are: (1) What portion, if any, of the amount of $1.5 million paid to Hughes Bagley (petitioner) in settlement of a suit against Iowa Beef Processors, Inc. (IBP), is allocable to punitive damages; (2) whether the $500,000 in punitive damages paid to petitioner pursuant to a judgment against IBP, and the portion, if any, of the $1.5 million paid to petitioner in settlement of his suit against IBP which is allocable to punitive damages, are…

2Cases cited30 opinions

  1. City of Newport v. Fact Concerts, Inc.Supreme Court of the United States · 1981
  2. Trans World Airlines, Inc. v. ThurstonSupreme Court of the United States · 1985
  3. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  4. Overnight Motor Transportation Co. v. MisselSupreme Court of the United States · 1942
  5. United States v. BurkeSupreme Court of the United States · 1992

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3Cited by72 opinions

  1. Hughes A. Bagley and Marilyn B. Bagley v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1997
  2. Gerstenbluth v. Credit Suisse Securities (USA) LLCCourt of Appeals for the Second Circuit · 2013
  3. Bernard C. Duse, Jr. v. International Business MacHines CorporationCourt of Appeals for the Second Circuit · 2001
  4. Kenseth v. CommissionerUnited States Tax Court · 2000
  5. Chamberlain Ex Rel. Chamberlain v. United StatesCourt of Appeals for the Fifth Circuit · 2005

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

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