Legal Opinion

Christine A. Byrne v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided August 22, 1989No. 89-1115PublishedCited by 30 opinions

1Opinion of the Court

OPINION OF THE COURT

COWEN, Circuit Judge.

Christine Byrne received $20,000 in 1981 in return for her agreement not to pursue Fair Labor Standards Act (“FLSA”) and state law wrongful discharge claims against her former employer. This appeal requires us to decide whether the Tax Court properly determined that one-half of these settlement proceeds represented taxable income. Because we conclude that the entire settlement is excludable under 26 U.S.C. § 104(a)(2), we will reverse the order of the Tax Court.

I

The facts of this case are discussed extensively in the Tax Court opinion, Byrne v.…

2Cases cited6 opinions

  1. Pierce v. Ortho Pharmaceutical Corp.Supreme Court of New Jersey · 1980
  2. James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
  3. Paul F. Roemer, Jr. And Marcia E. Roemer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  4. James Edward Bent v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1988
  5. William E. Brock, Secretary of Labor, United States Department of Labor v. The Claridge Hotel and CasinoCourt of Appeals for the Third Circuit · 1988

1 more not listed; retrieve them via the Exa API.

3Cited by30 opinions

  1. Frank E. & Mildred E. Rickel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
  2. Delaney v. CommissionerCourt of Appeals for the First Circuit · 1996
  3. Fremont G. Redfield v. Insurance Company of North AmericaCourt of Appeals for the Ninth Circuit · 1991
  4. Elizabeth A. Reese v. United StatesCourt of Appeals for the Federal Circuit · 1994
  5. Carmen Pistillo v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1990

25 more not listed; retrieve them via the Exa API.

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