Legal Opinion
Duffy v. United States
United States Court of Federal Claims
Decided February 13, 2015No. 14-288TPublishedCited by 5 opinions
1Opinion of the Court
Claim for refund of income tax paid on proceeds of a settlement agreement; “origin of the claim” doctrine; inapplicability of exclusion from taxation under I.R.C. § 104(a)(2); proceeds taxable as ordinary income and not capital gains
OPINION AND ORDER
LETTOW, Judge.
In this tax refund case, plaintiffs James P. and Beatriz N. Duffy (collectively, “the Duff-ys”) seek a refund of $13,049 in income taxes allegedly overpaid for tax year 2007. Am. Compl. ¶ 1, ECF No. 3. In their complaint, the Duffys maintain that the proceeds of an agreement entered by Mr. Duffy to settle a claim he had made were not…
2Cases cited66 opinions
- Ashcroft v. IqbalSupreme Court of the United States · 2009
- Bell Atlantic Corp. v. TwomblySupreme Court of the United States · 2007
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
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3Cited by5 opinions
- Wolens v. United StatesUnited States Court of Federal Claims · 2016
- Beatty v. United StatesUnited States Court of Federal Claims · 2015
- Bell v. United StatesDistrict Court, D. Connecticut · 2017
- Hill v. Secretary of Health and Human ServicesUnited States Court of Federal Claims · 2020
- Wade v. United StatesUnited States Court of Federal Claims · 2018