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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.
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Last modified: May 25, 2011