Legal Opinion
Commissioner of Internal Revenue v. Bonnie A. Miller
Court of Appeals for the Fourth Circuit
Decided September 21, 1990No. 17-2420PublishedCited by 65 opinions
1Opinion of the Court
MURNAGHAN, Circuit Judge:
The question presented in the case before us is whether the portion of a defamation action settlement properly attributed to punitive damages is excludable from gross income pursuant to 26 U.S.C. § 104(a)(2).
I
Bonnie A. Miller succeeded in obtaining a large settlement of two lawsuits brought for defamation and intentional infliction of emotional distress. The ad damnum for the first of the two suits, which Miller brought in the Superior Court of (now the Circuit Court for) Baltimore City, was $10,-000,000, with an additional claim of $10,-000,000 in punitive damages.…
2Cases cited19 opinions
- Gertz v. Robert Welch, Inc.Supreme Court of the United States · 1974
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Weiss v. StearnSupreme Court of the United States · 1924
14 more not listed; retrieve them via the Exa API.
3Cited by65 opinions
- Transportation Insurance Co. v. MorielTexas Supreme Court · 1994
- O'Gilvie v. United StatesSupreme Court of the United States · 1996
- Robinson v. CommissionerUnited States Tax Court · 1994
- Bagley v. CommissionerUnited States Tax Court · 1995
- Jack R. Hawkins, Cynthia J. Hawkins, Husband & Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1994
60 more not listed; retrieve them via the Exa API.