Stocks v. Commissioner
United States Tax Court
Petitioner wife (W) was a tenured associate professor at college S. In July 1983 and September 1983, W filed racial discrimination charges against college S with State and Federal agencies; W did not bring court suits on those charges. College S did not rehire W for the 1984-85 school year, and failed to notify W of its intentions by Feb. 1, 1984, as required by its faculty handbook.
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Petitioner wife (W) was a tenured associate professor at college S. In July 1983 and September 1983, W filed racial discrimination charges against college S with State and Federal agencies; W did not bring court suits on those charges. College S did not rehire W for the 1984-85 school year, and failed to notify W of its intentions by Feb. 1, 1984, as required by its faculty handbook. In 1984, W and college S entered into a settlement agreement whereby college S paid $ 24,000 to W in settlement of all claims against college S. 1. Held: The payment was received on account of a potential breach…
1Opinion of the Court
CHABOT, Judge:
Respondent determined a deficiency in Federal individual income taxes against petitioners for 1984 in the amount of $9,518,1 and additions to tax under section 6653(a)(1) (negligence, etc.) in the amount of $475.90, under section 6653(a)(2) in the amount of 50 percent of the interest on $9,518, and under section 6661(a) (substantial understatement of income tax) in the. amount of $2,379.50.
After concessions,2 the issues for decision are as follows:(1) Whether petitioners may exclude from gross income under section 104(a)(2) any part of the $24,000 received pursuant to a…
2Cases cited20 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. TaylorSupreme Court of the United States · 1935
- Mason K. Knuckles and Bernice A. Knuckles v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1965
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
15 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Robinson v. CommissionerUnited States Tax Court · 1994
- Delaney v. CommissionerCourt of Appeals for the First Circuit · 1996
- Kovacs v. CommissionerUnited States Tax Court · 1993
- Charles Francisco Cecilia Francisco v. United StatesCourt of Appeals for the Third Circuit · 2001
- McKay v. CommissionerUnited States Tax Court · 1994
37 more not listed; retrieve them via the Exa API.