- 6 - and certain other miscellaneous items. The $881,226.03 was disbursed by Howard to Ragatz out of the trust account. The details of the disbursement to Mangum are not in the record. Petitioners did not report their punitive damages awards as taxable income on their respective 1992 tax returns, although the Benci-Woodwards and the Mangums disclosed the awards on their returns. In addition, petitioners did not report in full their interest on punitive damages on their respective 1992 returns. Respondent timely issued notices of deficiency to petitioners. Among other adjustments, respondent determined that punitive damages and related interest were fully includable in petitioners' gross income pursuant to section 61. Petitioners have since conceded that their punitive damages, and related interest, are includable in gross income in the amounts determined by respondent. See O'Gilvie v. United States, 519 U.S. 79 (1996). Respondent also determined that the Benci-Woodwards, the Mangums, and the Ragatzes were entitled to miscellaneous itemized deductions, subject to the 2-percent floor provided by section 67(a), for attorney's fees and costs attributable to the punitive damages awards in the amounts of $670,135, $626,448, and $609,767, respectively. However, for AMT purposes, respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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