-11-
for the Sixth Circuit held that a portion of a judgment awarded
to a taxpayer and paid to the taxpayer’s lawyer under a
contingent fee arrangement was not includable in the taxpayer’s
gross income. The Court reasoned that the taxpayer’s contingent
fee agreement operated under applicable State (Michigan) law as a
lien on the portion of the judgment to be recovered and
transferred the ownership of that portion to the lawyer. We do
not read the Court of Appeals’ opinion in Estate of Clarks to
support petitioners’ position as to the court costs and claimed
medical expenses. We hold against petitioners on this issue.
We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011