Ford Motor Co. v. Commissioner
United States Tax Court
P settled various tort claims by entering into "structured settlements" with the tort claimants. P was obligated under the terms of the settlement agreements to make a series of payments to each of the tort claimants over various periods, the longest of which was 58 years. P purchased single premium annuity contracts to fund the series of payments P was obligated to make to the tort claimants.
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P settled various tort claims by entering into "structured settlements" with the tort claimants. P was obligated under the terms of the settlement agreements to make a series of payments to each of the tort claimants over various periods, the longest of which was 58 years. P purchased single premium annuity contracts to fund the series of payments P was obligated to make to the tort claimants. The present value of P's obligations to the tort claimants does not exceed the amount P paid for the annuity contracts. P, an accrual basis taxpayer, claims a deduction for its 1980 taxable year for the…
1Opinion of the Court
OPINION
Wells, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the 1970 taxable year in the amount of $3,300,151. Petitioners are hereinafter collectively referred to as petitioner. The deficiency is based on respondent’s disallowance of a portion of the deductions claimed by petitioner with respect to obligations it incurred under “structured settlements” it reached in 19801 with tort claimants.2 Petitioner claims deductions for the accrual of the total future payments to the tort claimants under the structured settlements. Respondent determined that…
2Cases cited36 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- United States v. Southwestern Cable Co.Supreme Court of the United States · 1968
- Bowen v. RoySupreme Court of the United States · 1986
- Rainwater v. United StatesSupreme Court of the United States · 1958
31 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995
- Keith v. CommissionerUnited States Tax Court · 2000
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- Exxon Mobil Corp. v. CommissionerUnited States Tax Court · 2000
- Arrowhead Mt. Getaway v. CommissionerUnited States Tax Court · 1995
20 more not listed; retrieve them via the Exa API.