-9- By the end of 1999, the bank had paid petitioner $500,000, and petitioner had paid Mr. McKenna $75,000 from the amount received. Sometime during 1999, petitioner contacted a Nevada Congressman’s office to inquire about the taxability of the settlement proceeds and received a response from a representative of a local Taxpayer Advocate Service office in return. Petitioner was dissatisfied with the clarity of that office’s response, and he sent a letter dated January 20, 2000, to the District Director of the Internal Revenue Service (IRS) in Phoenix, Arizona, again inquiring about the taxability of the proceeds he received for violation of his “civil rights to a full and impartial tribunal”. On or about February 11, 2000, the District Director responded by letter to petitioner’s inquiry. The letter informed petitioner of the rules generally governing the taxation of court awards and settlements, and stated: If this information is insufficient for your needs, there are other avenues you can follow to receive a more formal opinion on the taxability of the funds received in the settlement. You can request an opinion letter, private letter ruling, or a determination letter. * * * The user fee for a ruling or letter * * * would be * * * $2,500, if your total income is over $150,000. Petitioner did not request a ruling or letter. On or about April 17, 2000, petitioner filed a Form 1040, U.S. Individual Income Tax Return, for 1999. Petitioner did not include the $500,000 of settlement proceeds in the gross income he reported on his 1999 return. Petitioner attached a statementPage: 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