- 3 - Docket No. 4185-96 (the Mangums) Year Deficiency 1992 $314,873 Docket No. 8265-96 (the Ragatzes) Year Deficiency 1992 $316,965 Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts are rounded to the nearest dollar. After concessions by petitioners, the issues remaining for decision are: (1) Whether legal expenses attributable to petitioners' receipt of punitive damages constitute miscellaneous itemized deductions within the meaning of section 67(b); if so, (2) whether such deductions are subject to disallowance for purposes of computing petitioners' alternative minimum tax (AMT) liability; and (3) whether attorney's fees and costs may be excluded from gross income under the facts of this case. These cases were submitted fully stipulated. The petitioners resided in California at the time they filed their petitions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011