Legal Opinion
Craig Patrick & Michele Patrick v. Commissioner
United States Tax Court
Decided February 24, 2014No. 16387-12Published
1Opinion of the Court
142 T.C. No. 5
UNITED STATES TAX COURT CRAIG PATRICK AND MICHELE PATRICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16387-12. Filed February 24, 2014. P-H received two monetary awards for bringing qui tam complaints filed under the False Claims Act (FCA),
31 U.S.C. sec. 3730
(2006). Ps reported the awards as capital gains. R issued a deficiency notice that disallowed capital gains treatment and characterized the awards as other income. R contends that a qui tam award does not result from the sale or exchange of a capital asset, citing I.R.C. sec. 1222(1), (3). Ps…
2Cases cited19 opinions
- Vermont Agency of Natural Resources v. United States Ex Rel. StevensSupreme Court of the United States · 2000
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. BrownSupreme Court of the United States · 1965
- National Railroad Passenger Corp. v. Atchison, Topeka & Santa Fe Railway Co.Supreme Court of the United States · 1985
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
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