P & X Mkts. v. Commissioner
United States Tax Court
P, a corporation, filed a lawsuit against various defendants alleging breach of contract, malicious prosecution, intentional interference with business relationship, fraud, and violation of fiduciary and statutory duties. P received $ 850,000 to settle the suit, and it paid $ 198,367 in legal fees in connection therewith. On its Federal income tax return, P included $ 83,608 of the settlement proceeds in its gross income.
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P, a corporation, filed a lawsuit against various defendants alleging breach of contract, malicious prosecution, intentional interference with business relationship, fraud, and violation of fiduciary and statutory duties. P received $ 850,000 to settle the suit, and it paid $ 198,367 in legal fees in connection therewith. On its Federal income tax return, P included $ 83,608 of the settlement proceeds in its gross income. P relied on sec. 104(a)(2), I.R.C., to exclude the remaining proceeds (net of the legal fees) from its gross income. R determined that P's gross income includes the total…
1Opinion of the Court
P & X MARKETS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
P & X Mkts. v. Commissioner
Docket No. 15836-95.
United States Tax Court
106 T.C. 441; 1996 U.S. Tax Ct. LEXIS 30; 106 T.C. No. 26;
June 13, 1996, Filed
P, a corporation, filed a lawsuit against various defendants alleging breach of contract, malicious prosecution, intentional interference with business relationship, fraud, and violation of fiduciary and statutory duties. P received $ 850,000 to settle the suit, and it paid $ 198,367 in legal fees in connection therewith. On its Federal income tax return, P included $…
2Cases cited14 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Associated Press v. United StatesSupreme Court of the United States · 1945
- United States v. BurkeSupreme Court of the United States · 1992
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