Legal Opinion

Glenshaw Glass Co. v. Commissioner

United States Tax Court

Decided August 13, 1952No. Docket No. 30821Published

1. Where a lump sum of money is received in settlement of various claims, an allocation of specific amounts to each of the several claims is necessary and proper. 2. Sums received in settlement of punitive damages do not constitute taxable income. 3. Sums received in settlement of claims for anticipated profits are taxable as ordinary income.

1Opinion of the Court

Glenshaw Glass Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Glenshaw Glass Co. v. Commissioner

Docket No. 30821

United States Tax Court

18 T.C. 860; 1952 U.S. Tax Ct. LEXIS 124;

August 13, 1952, Promulgated

Decision will be entered under Rule 50.

1. Where a lump sum of money is received in settlement of various claims, an allocation of specific amounts to each of the several claims is necessary and proper.

2. Sums received in settlement of punitive damages do not constitute taxable income.

3. Sums received in settlement of claims for anticipated profits are taxable as ordinary…

2Cases cited21 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Hartford-Empire Co. v. United StatesSupreme Court of the United States · 1945
  4. Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
  5. Helvering v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1942

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