Fono v. Commissioner
United States Tax Court
Petitioners, developers of the Magic Pan restaurant concept and owners of equipment and recipes, sold their restaurant business to Quaker in 1969 in consideration of approximately $ 277,000 in cash and employment and royalty agreements.
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Petitioners, developers of the Magic Pan restaurant concept and owners of equipment and recipes, sold their restaurant business to Quaker in 1969 in consideration of approximately $ 277,000 in cash and employment and royalty agreements. Dissatisfied with the operation of the 1969 agreements, petitioners in 1972 negotiated a settlement under which the employment and bonus agreements were terminated, and petitioners received $ 425,000, none of which was allocated to claimed mental distress or other personal injuries. Again dissatisfied, petitioners in 1975 sued Quaker and in 1980 settled the…
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for 1972 in the amount of $167,576. Other issues having been resolved by agreement between the parties,1 the only issue remaining for decision is what part, if any, of a payment received by petitioners in 1972 in settlement of a dispute with the Quaker Oats Co. should be allocated to personal injuries within the meaning of section 104(a)(2).2
FINDINGS OF FACT
1. General
Petitioners Laszlo Fono and Paulette Fono are husband and wife. They filed a joint Federal income tax return for 1972 with the Internal…
2Cases cited35 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Mason K. Knuckles and Bernice A. Knuckles v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1965
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
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3Cited by73 opinions
- Threlkeld v. CommissionerUnited States Tax Court · 1986
- Paul F. Roemer, Jr. And Marcia E. Roemer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Robinson v. CommissionerUnited States Tax Court · 1994
- Metzger v. CommissionerUnited States Tax Court · 1987
- Bent v. CommissionerUnited States Tax Court · 1986
68 more not listed; retrieve them via the Exa API.