William J. Goeden and Carol S. Goeden - Page 9

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          or implied, and libel, slander, defamation, damage to reputation,           
          and intentional or negligent infliction of emotional distress.              
               Pursuant to the settlement agreement, petitioner received              
          from the credit union a lump-sum payment of $50,000 on September            
          15, 1988, and monthly payments totaling $14,000 in 1988, $42,000            
          in 1989, and $42,000 in 1990.                                               
               In an attachment to their Federal income tax returns for               
          each of the years 1988, 1989, and 1990, relying on the advice of            
          their certified public accountant from KPMG Peat Marwick, the               
          firm which prepared them, petitioners reported an amount under              
          "miscellaneous other income" which was 25 percent of the monthly            
          payments as the "taxable portion of settlement with State Central           
          Credit Union".  They also reported in 1988 an amount that was 25            
          percent of the $50,000 lump-sum payment.  They claimed a                    
          deduction of $13,750 for attorney's fees paid in 1988.  The                 
          returns did not disclose the full amount of the payments received           
          by petitioner or the percentage reported.  The returns did not              
          report as income any part of the value of petitioner's health and           
          life insurance coverage.                                                    
               On or about December 9, 1991, petitioners filed amended                
          Federal income tax returns for 1988, 1989, and 1990, containing             
          the following explanation:                                                  
               On the return as originally filed the taxpayer had included            
               in Other Income the "taxable portion" of settlement proceeds           
               received from State Central Union.  The settlement proceeds            
               arose from an employment discrimination claim.                         




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