Legal Opinion
Frank E. & Mildred E. Rickel v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided April 3, 1990No. 19-1969PublishedCited by 100 opinions
1Opinion of the Court
OPINION OF THE COURT
COWEN, Circuit Judge.
The appellant Frank E. Rickel (“the taxpayer”) 1 received $80,000 from his former employer in 1983 and $25,000 in 1984 pursuant to a settlement of his Age Discrimination in Employment Act (“ADEA”) lawsuit. This appeal requires us to decide whether the United States Tax Court properly determined that one-half of this settlement represented taxable income. Because we conclude that the entire settlement amount is excludable under 26 U.S.C. § 104(a)(2) 2 , we will reverse the order of the Tax Court.
I
The relevant facts of this case are not contested. The…
2Cases cited46 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Wilson v. GarciaSupreme Court of the United States · 1985
- Price Waterhouse v. HopkinsSupreme Court of the United States · 1989
- Albemarle Paper Co. v. MoodySupreme Court of the United States · 1975
- Trans World Airlines, Inc. v. ThurstonSupreme Court of the United States · 1985
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3Cited by100 opinions
- Spectrum Sports, Inc. v. McQuillanSupreme Court of the United States · 1993
- United States v. BurkeSupreme Court of the United States · 1992
- Abrams v. Lightolier Inc.Court of Appeals for the Third Circuit · 1995
- John D. Starceski, at No. 94-3208 v. Westinghouse Electric Corporation, at No. 94-3182Court of Appeals for the Third Circuit · 1995
- In Re Billie Vester Rasbury, Debtor. Billie Vester Rasbury Bill's Forestry Service, Inc. v. Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1994
95 more not listed; retrieve them via the Exa API.