- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011