106 T.C. No. 26 UNITED STATES TAX COURT P & X MARKETS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15836-95. Filed June 13, 1996. P, a corporation, filed a lawsuit against various defendants alleging breach of contract, malicious prosecution, intentional interference with business relationship, fraud, and violation of fiduciary and statutory duties. P received $850,000 to settle the suit, and it paid $198,367 in legal fees in connection therewith. On its Federal income tax return, P included $83,608 of the settlement proceeds in its gross income. P relied on sec. 104(a)(2), I.R.C., to exclude the remaining proceeds (net of the legal fees) from its gross income. R determined that P’s gross income includes the total proceeds, less the legal fees. Held: None of the proceeds are excludable from P’s gross income under sec. 104(a)(2), I.R.C., because the settlement proceeds were not received on account of a personal injury.Page: 1 2 3 4 5 6 7 8 Next
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