Simpson v. Comm'r
United States Tax Court
P-W sued E, her employer, for employment discrimination under California's Fair Employment and Housing Act (FEHA), claiming, among other things, that she was entitled to compensatory damages for, among other things, physical injuries. After the State court dismissed all but one claim alleged in the suit, P-W's attorney concluded that P-W would not be able to extract a settlement from E on the basis of the one remaining FEHA claim.
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P-W sued E, her employer, for employment discrimination under California's Fair Employment and Housing Act (FEHA), claiming, among other things, that she was entitled to compensatory damages for, among other things, physical injuries. After the State court dismissed all but one claim alleged in the suit, P-W's attorney concluded that P-W would not be able to extract a settlement from E on the basis of the one remaining FEHA claim. P-W's attorney learned, however, that P-W was eligible for workers' compensation benefits under California's workers' compensation laws. On that basis alone, P-W…
1Opinion of the Court
Laro, Judge-.
Respondent determined a Federal income tax deficiency of $73,407 for 2009 and an accuracy-related penalty under section 6662(a) of $14,681.1 Petitioners, while residing in California, timely petitioned this Court to redetermine respondent’s determination. Following respondent’s concession that petitioners are not liable for the accuracy-related penalty, we decide: (1) whether any portion of $250,000 2 petitioners received in 2009 in settlement of a dispute with Sears, Roebuck & Co. (Sears) is excludable from their gross income under section 104(a)(1) or (2). We hold it is not…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
16 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Perez v. CommissionerUnited States Tax Court · 2015
- Green v. Comm'rUnited States Tax Court · 2014
- Braddock v. Comm'rUnited States Tax Court · 2016
- Kathleen S. Simpson & George T. Simpson v. CommissionerUnited States Tax Court · 2013
- Lawson v. Comm'rUnited States Tax Court · 2015
1 more not listed; retrieve them via the Exa API.