- 17 - v. Commissioner, supra (involving a civil lawsuit for malicious prosecution); Roemer v. Commissioner, 716 F.2d 693 (9th Cir. 1983), revg. 79 T.C. 398 (1982) (involving a civil suit for injury to a person's reputation caused by defamatory statements constituting libel). The law was unsettled with respect to the excludability of claims based on age discrimination. See Downey v. Commissioner, 97 T.C. 150 (1991), supplemented by 100 T.C. 634 (1993), revd. and remd. 33 F.3d 836 (7th Cir. 1994). It is problematic whether petitioners adequately disclosed the item regarding the settlement payments in their 1988 return. While it was not a full and detailed disclosure, we are inclined to view it as adequate because respondent was alerted to the fact that petitioner had received settlement payments from the credit union, some taxable and some nontaxable. The disclosure in the attachment to the return led to respondent's audit of the item which in turn resulted in the principal adjustment contained in the notice of deficiency. Accordingly, we hold that petitioners are not liable for the addition to tax under section 6661(a) for 1988. Issue 4. Section 6662(a) Accuracy-Related Penalties Respondent determined that petitioners are liable for accuracy-related penalties for negligence under section 6662(a)(1) for 1989, and for a substantial understatement of income tax under section 6662(a)(2) and negligence under sectionPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011