- 10 - OF ALASKA, DEPARTMENT OF PUBLIC SAFETY, JOHN HARMAN * * * of and from all actions, causes of action, suits, controversies, claims, and demands of every kind and nature, mature or to mature in the future, for and by reason of any damages, costs, expenses, and compensation, whether for insurance proceeds, personal injury, bodily injury, property damage, out-of-pocket expenses, loss of earnings, loss of use, loss of consortium, loss of services, attorney’s fees, punitive damages, or bad-faith handling, or any other thing whatsoever, arising out of an incident occurring on or about June 10, 1986, and any and all claims embodied in David C. Norton v. John E. Harmon [sic], et al. * * * * * * * * * * This release notwithstanding, nothing in this agreement shall restrict the undersigned’s right to apply * * * for a limited entry permit for the Norton Sound beach seine herring sac roe fishery, nor shall it prevent the undersigned from filing an administrative appeal with respect to such a permit * * * The net amount Mr. Norton received in 1993 (after reductions for attorney’s fees and costs) was $26,280. The Nortons did not report the settlement proceeds on their 1993 Federal income tax return. In the notice of deficiency, respondent determined that the proceeds received from the settlement of the Harman lawsuit were taxable to Mr. Norton as compensation for lost fishing income. Section 61(a) requires that taxpayers include in their gross income all income from whatever source derived, absent a contrary provision in the Internal Revenue Code (Code). Section 104(a)(2) is one such provision. Pursuant to section 104(a)(2), gross income does not include the amount of any damages received (whether by suit or agreement) on account of personal injuries or sickness.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