Legal Opinion

Rosen v. United States

District Court, W.D. Virginia

Decided September 23, 1986No. Civ. A. 84-0074-CPublishedCited by 2 opinions

1Opinion of the Court

MEMORANDUM OPINION

MICHAEL, Judge.

Kenneth S. Rosen [hereinafter “taxpayer”] and his wife, Lou Hill Davidson, 1 brought this suit seeking to recover $20,-755.00 in income taxes paid for the calendar year 1976 and $168,221.00 in income taxes paid for the calendar year 1977. The question presented is whether the sums received by taxpayer upon termination of his employment due to disability should be included in gross income. It is the opinion of this court that such sums should not be so included.

Taxpayer was employed by Warner Communications, Inc. [hereinafter WCI], pursuant to an employment…

2Cases cited13 opinions

  1. Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
  2. Cornell v. CoyneSupreme Court of the United States · 1904
  3. United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
  4. Helvering v. Ohio Leather Co.Supreme Court of the United States · 1942
  5. Frank S. Watts and Barbara M. Watts v. United StatesCourt of Appeals for the Ninth Circuit · 1983

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3Cited by2 opinions

  1. Kenneth S. Rosen Lou Hill Davidson, (Johnnye) v. United StatesCourt of Appeals for the Fourth Circuit · 1987
  2. Paul v. United StatesDistrict Court, E.D. Michigan · 1988

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