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federal or state wage and hour laws; and claims
that * * * [Okabena] or the Investments engaged in
conduct prohibited on any other basis under any
federal, state, or local statute, ordinance, or
regulation;
4. All claims for alleged unpaid compensation,
expenses, and employee benefits; wrongful
discharge; breach of contract; breach of implied
contract; breach of a covenant of good faith and
fair dealing; breach of fiduciary duty; promissory
or equitable estoppel; defamation; intentional or
negligent infliction of emotional distress; fraud;
negligent misrepresentation; negligence; assault
and battery; false imprisonment; invasion of
privacy; interference with contractual or business
relationships; and any other wrongful employment
practices;
5. All claims for accountings, distributions,
payments, and any other compensation from the
Investments, except from Okabena Partnership V-8
and Energy Corporation E-2; and
6. All claims for attorneys’ fees, liquidated
damages, punitive damages, costs, and
disbursements.
[Emphasis added.]
The Notice of Deficiency
In his statutory notice of deficiency, respondent
recharacterized the lump-sum payments as ordinary income taxable
to petitioner when received in 1993 and 1994 and also determined
that the liquidation payment was taxable to petitioner as
proceeds from the sale or exchange of various capital assets;
i.e., petitioner’s interests in various Okabena partnerships and
investments.
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Last modified: May 25, 2011