Lee Turzillo and Lucille Turzillo v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
SHACKELFORD MILLER, Jr., Circuit Judge.
The taxpayers, Lee Turzillo (hereinafter referred to as Turzillo) and his wife, Lucille Turzillo, seek a review of the decision of the Tax Court which held that $95,000.00 of a total of $106,-233.36, received by Turzillo in a settlement of a law suit for breach of contract, was ordinary income, taxable as such rather than capital gain.
The facts, which are not in dispute, are stated in detail in the Memorandum, Findings of Fact, and Opinion of the Tax Court, reported at T.C. Memo 1963-317, to which reference is made. For the purposes of this opinion, we…
2Cases cited26 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
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3Cited by14 opinions
- Belz Inv. Co. v. CommissionerUnited States Tax Court · 1979
- United States Freight Company and Subsidiaries v. The United StatesUnited States Court of Claims · 1970
- Rothstein v. CommissionerUnited States Tax Court · 1988
- Herbert B. Cline, Jr., and Brisy Cline, John C. Cline and Mildred Cline v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Wachner v. CommissionerUnited States Tax Court · 1995
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