T.C. Memo. 1998-395 UNITED STATES TAX COURT IVOR F. AND DEBRA A. BENCI-WOODWARD, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3769-96, 4185-96, Filed November 9, 1998. 8265-96. In these consolidated cases, R determined deficiencies in Ps' Federal income taxes for their 1992 taxable year due to their failure to include in gross income certain punitive damages and interest arising out of a State court lawsuit. (Ps now concede that all amounts received as punitive damages, plus interest, are includable in gross income as determined by R. See O'Gilvie v. United States, 519 U.S. 79 (1996).) R allowed Ps miscellaneous itemized deductions for legal fees and costs attributable to their punitive damages awards pursuant to sec. 67, I.R.C. However, in computing Ps' alternative minimum tax (AMT) adjustments, R disallowed their miscellaneous itemized deductions pursuant to sec. 56(b)(1)(A)(i), I.R.C. 1 Cases of the following petitioners are consolidated herewith: Laurentz J. and Barbara Mangum, docket No. 4185-96, and Jose and Dianne M. Ragatz, docket No. 8265-96.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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