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deduction is lacking. Talley Indus., Inc. & Consol. Subs. v.
Commissioner, 116 F.3d at 387-388. The record shows that the
parties did not agree whether the portion of the settlement in
excess of the Government's "singles" damages would constitute
compensation to the Government for its losses or a penalty
against Stencel. It thus follows that petitioner has failed to
establish entitlement to a deduction for the disputed portion of
the settlement.
Consistent with the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011