Renner v. Commissioner
United States Tax Court
In 1982, P sued his former employer, M, for age discrimination under the Age Discrimination in Employment Act (ADEA). In 1985, prior to trial, M settled with P, and agreed to pay P $ 25,000 a year for 10 years, beginning in 1985. On his 1985 and 1986 Federal income tax returns, P deducted legal fees incurred in connection with the lawsuit. P paid taxes on the $ 25,000 payment for 1989, the year in issue. P subsequently filed for and received a refund of such taxes.
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In 1982, P sued his former employer, M, for age discrimination under the Age Discrimination in Employment Act (ADEA). In 1985, prior to trial, M settled with P, and agreed to pay P $ 25,000 a year for 10 years, beginning in 1985. On his 1985 and 1986 Federal income tax returns, P deducted legal fees incurred in connection with the lawsuit. P paid taxes on the $ 25,000 payment for 1989, the year in issue. P subsequently filed for and received a refund of such taxes. R later issued a report to P stating that the $ 25,000 payment was taxable income; P protested this report. R's Appeals Office…
1Opinion of the Court
DALE F. RENNER AND KATHRYN A. RENNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Renner v. Commissioner
Docket No. 4663-93
United States Tax Court
T.C. Memo 1994-263; 1994 Tax Ct. Memo LEXIS 264; 67 T.C.M. (CCH) 3072;
June 8, 1994, Filed
In 1982, P sued his former employer, M, for age discrimination under the Age Discrimination in Employment Act (ADEA). In 1985, prior to trial, M settled with P, and agreed to pay P $ 25,000 a year for 10 years, beginning in 1985. On his 1985 and 1986 Federal income tax returns, P deducted legal fees incurred in connection with the lawsuit.
P paid…
2Cases cited32 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Dobson v. CommissionerSupreme Court of the United States · 1944
- United States v. BurkeSupreme Court of the United States · 1992
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
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