Woodsum v. Comm'r
United States Tax Court
In 2006 Ps received gain of $3.4 million upon the termination of a "swap" transaction. P-H was personally involved in terminating the transaction and received from the payor a Form 1099-MISC, Miscellaneous Income, that reported the payment. Ps retained a firm with a lawyer and a certified public accountant to prepare their 2006 income tax return.
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In 2006 Ps received gain of $3.4 million upon the termination of a "swap" transaction. P-H was personally involved in terminating the transaction and received from the payor a Form 1099-MISC, Miscellaneous Income, that reported the payment. Ps retained a firm with a lawyer and a certified public accountant to prepare their 2006 income tax return. Ps gave to the firm all the 160-plus information returns they had received from third-party payors, including the Form 1099-MISC reporting the $3.4 million. The 115-page return that the firm prepared reported $29.2 million of adjusted gross income…
1Opinion of the Court
STEPHEN G. WOODSUM AND ANNE R. LOVETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Woodsum v. Comm'r
Docket No. 18934-09.
United States Tax Court
136 T.C. 585; 2011 U.S. Tax Ct. LEXIS 31; 136 T.C. No. 29;
June 13, 2011, Filed
Decision will be entered for respondent.
In 2006 Ps received gain of $3.4 million upon the termination of a "swap" transaction. P-H was personally involved in terminating the transaction and received from the payor a Form 1099-MISC, Miscellaneous Income, that reported the payment. Ps retained a firm with a lawyer and a certified public accountant to prepare…
2Cases cited8 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Metra Chem Corp. v. CommissionerUnited States Tax Court · 1987
- Magill v. CommissionerUnited States Tax Court · 1978
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