Robert L. Allum - Page 9

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          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 statement            





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