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sustain respondent's disallowance of the wagering losses
claimed on petitioner's 1991 return.
Lump-Sum Payment From FBI
The next issue is whether petitioner is entitled to
exclude from gross income or deduct any or all of the lump-
sum payment received from the FBI in the amount of
$100,000. Petitioner acknowledges that he received the
lump-sum payment, and he testified candidly: "I know I owe
taxes on it." He testified that the lump-sum payment was
paid in part as his share of the property seized by the
Government during the investigation, in part as considera-
tion for refusing to join the witness protection program,
and in part as reimbursement for the expenses of relocating
his family. In his posttrial brief, petitioner focuses on
the last of the above three reasons for the lump-sum
payment, relocation expenses. He argues that he "incurred
substantial expenses and cost associated with moving his
family" and that "an allowance for relocation expenses"
should be taken into account in computing the taxable
amount of this lump-sum payment. Petitioner's brief
states:
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