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to exclude from the gross income reported on their 1994
return the proceeds of a judgment in a State court action
in the amount of $314,173.91; (2) if not, whether
petitioners may exclude from their gross income for 1994 a
portion of the proceeds of the judgment equal to the amount
of the attorney's fees paid under a retainer agreement to
one of the attorneys who represented them in the State
court action; and (3) whether the alternative minimum tax
imposed by section 55 violates the Constitution of the
United States. All section references are to the Internal
Revenue Code as in effect during 1994, and all Rule
references are to the Tax Court Rules of Practice and
Procedure.
The facts have been fully stipulated by the parties
and are so found. The stipulated facts and the accompany-
ing exhibits are incorporated into this opinion by this
reference.
Petitioners were husband and wife at the end of 1994,
the taxable year at issue, and they filed a joint return
for that year. In this opinion, references to petitioner
are to Mr. Jack Freeman.
In 1991, after 34 years of service, petitioner was
summarily fired by his employer, Thrifty Corp. (Thrifty),
a corporation that operates a large chain of retail stores.
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