Legal Opinion
Campbell v. Commissioner
Court of Appeals for the Eleventh Circuit
Decided September 28, 2011No. 10-13677PublishedCited by 26 opinions
1Per curiam
Taxpayer Albert D. Campbell was awarded and received a net $5.25 million qui tam payment from the government as a “relator” in two lawsuits settled against government contractor Lockheed Martin (Lockheed) under the False Claims Act (FCA), 31 U.S.C. §§ 3729-3733 (2006). Campbell asserted that the award was not taxable. 1
The Tax Court disagreed. It held that the entire amount was includable in Campbell’s gross income as the equivalent of a reward, Roco v. Comm’r, 121 T.C. 160, 164, 2003 WL 22100687 (2003), pursuant to 1.R.C. § 61(a); and (2) that he was liable for an accuracy-related penalty…
2Cases cited10 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Vermont Agency of Natural Resources v. United States Ex Rel. StevensSupreme Court of the United States · 2000
- Green v. CommissionerCourt of Appeals for the Fifth Circuit · 2007
- Estate of Jelke v. CommissionerCourt of Appeals for the Eleventh Circuit · 2007
- Roco v. Comm'rUnited States Tax Court · 2003
5 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- William E. Gustashaw, Jr. v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- Lizzie W. Calloway v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- Highpoint Tower Technology Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
- Stromme v. Comm'rUnited States Tax Court · 2012
- Curtis Inv. Co. v. Comm'rCourt of Appeals for the Eleventh Circuit · 2018
21 more not listed; retrieve them via the Exa API.