-31-
hold that the entire settlement amount, including the portion
petitioner paid to his attorney pursuant to a contingent fee
agreement, must be included in petitioner’s gross income. See
Helvering v. Horst, 311 U.S. 112 (1940); Lucas v. Earl, 281 U.S.
111 (1930). We have carefully considered all remaining arguments
made by the parties for results contrary to those expressed
herein and, to the extent not discussed above, conclude that
those arguments are without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Last modified: May 25, 2011