Legal Opinion
Ernest and Mary C. Horton v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 29, 1994No. 93-1928PublishedCited by 15 opinions
1Opinion of the CourtBailey Brown, Senior Circuit Judge, joined by Siler, Circuit Judge,
KENNEDY, Circuit Judge (pp. 632-33), delivered a separate dissenting opinion.
BAILEY BROWN, Senior Circuit Judge.
Appellant Commissioner of Internal Revenue (“the Commissioner”) appeals from a Tax Court decision in favor of Appellees Ernest and Mary C. Horton (“the Hortons” or “the Taxpayers”) which held that the Hor-tons were entitled to exclude from their gross income punitive damages received in 1985 under pre-revision section 104(a)(2) of the Internal Revenue Code.1 We conclude *626that the Tax Court did not err and therefore affirm.
I
The Tax Court summarized the facts of the case, to which the…
2Cases cited19 opinions
- United States v. BurkeSupreme Court of the United States · 1992
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Threlkeld v. CommissionerUnited States Tax Court · 1986
- Horton v. Union Light, Heat & Power Co.Kentucky Supreme Court · 1985
- Paul F. Roemer, Jr. And Marcia E. Roemer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
14 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Bagley v. CommissionerUnited States Tax Court · 1995
- Ray L. Wesson, Estate of Ray Wesson, Deceased, E. Hall, Administrator v. United StatesCourt of Appeals for the Fifth Circuit · 1995
- Estate of Moore v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- John A. Schmitz, Mary B. Schmitz v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1994
- Shaltz v. Comm'rUnited States Tax Court · 2003
10 more not listed; retrieve them via the Exa API.