WOLFSON v. COMMISSIONER
United States Tax Court
1. P instituted suit against his former employer for libel and slander, asking for equitable relief and damages, including $144,000 for lost income and damages to his professional reputation. The Wayne County Circuit Court awarded petitioner $175,000 damages based on lost income but no equitable relief. The employer appealed and while appeal was pending, the parties settled out of court for $105,000 and all the equitable relief prayed.
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1. P instituted suit against his former employer for libel and slander, asking for equitable relief and damages, including $144,000 for lost income and damages to his professional reputation. The Wayne County Circuit Court awarded petitioner $175,000 damages based on lost income but no equitable relief. The employer appealed and while appeal was pending, the parties settled out of court for $105,000 and all the equitable relief prayed. The settlement did not allocate the payments. Held, the $105,000 payment was made on account of damage to P's professional reputation. In the absence of any…
1Opinion of the Court
WILLIAM Q. WOLFSON AND ELIZABETH WOLFSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
WOLFSON v. COMMISSIONER
Docket No. 7711-74.
United States Tax Court
T.C. Memo 1978-445; 1978 Tax Ct. Memo LEXIS 65; 37 T.C.M. (CCH) 1847-14;
November 7, 1978, Filed
1. P instituted suit against his former employer for libel and slander, asking for equitable relief and damages, including $144,000 for lost income and damages to his professional reputation. The Wayne County Circuit Court awarded petitioner $175,000 damages based on lost income but no equitable relief. The employer appealed and while…
2Cases cited35 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Fausner v. CommissionerSupreme Court of the United States · 1973
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
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