Goode v. Comm'r
United States Tax Court
Ps did not include in their 2001 Federal income tax return payments totaling $ 135,000, remitted pursuant to a settlement agreement entered into between petitioner-husband (P-H) and the District of Columbia. Under the terms of the settlement agreement, the proceeds at issue were designated as attorney's fees and "claims and out-of-pocket expenses", and were to be considered as non-taxable amounts pursuant to sec. 104(a)(2), I.R.C.
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Ps did not include in their 2001 Federal income tax return payments totaling $ 135,000, remitted pursuant to a settlement agreement entered into between petitioner-husband (P-H) and the District of Columbia. Under the terms of the settlement agreement, the proceeds at issue were designated as attorney's fees and "claims and out-of-pocket expenses", and were to be considered as non-taxable amounts pursuant to sec. 104(a)(2), I.R.C. Ps were not furnished with a timely, properly issued Form 1099-Misc., Miscellaneous Income. Held: Ps are not entitled to exclude the $ 135,000 settlement payment…
1Opinion of the Court
JESSE AND TAWARA GOODE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Goode v. Comm'r
No. 9914-04
United States Tax Court
T.C. Memo 2006-48; 2006 Tax Ct. Memo LEXIS 48; 91 T.C.M. (CCH) 901;
March 21, 2006, Filed
Ps did not include in their 2001 Federal income tax return
payments totaling $ 135,000, remitted pursuant to a settlement
agreement entered into between petitioner-husband (P-H) and the
District of Columbia. Under the terms of the settlement
agreement, the proceeds at issue were designated as attorney's
fees and "claims and out-of-pocket expenses", and were to be
considered as…
2Cases cited20 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- United States v. BurkeSupreme Court of the United States · 1992
- Commissioner v. SchleierSupreme Court of the United States · 1995
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Threlkeld v. CommissionerUnited States Tax Court · 1986
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