121 T.C. No. 10
UNITED STATES TAX COURT
EMMANUEL L. ROCO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8470-01. Filed September 11, 2003.
Petitioner (P) sued the New York University
Medical Center (NYUMC) in a qui tam action under the
False Claims Act, 31 U.S.C. secs. 3729-3733 (2000).
NYUMC agreed to pay $15,500,000 to the United States to
settle the case. The United States paid $1,568,087 of
the settlement proceeds to P in 1997.
The parties dispute whether the $1,568,087 qui tam
payment is includable in P’s gross income for 1997.
Held: The $1,568,087 payment is includable in P’s
gross income for 1997.
Held, further, P is liable for the accuracy-
related penalty under sec. 6662(a), I.R.C., for 1997.
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