- 7 - grounds that related to his employment as counterclaims against Prudential, including breach of contract, breach of the covenant of good faith and fair employment, fraud, negligent misrepresentation in petitioner’s hiring, and punitive damages. During 1990, the arbitration proceeding was settled. Under the settlement, Prudential released petitioner from his obligation to repay the $325,000 loan balance, and petitioner agreed to drop his employment-related claims. Petitioner’s attorney wrote petitioner a letter stating that the $325,000 would be reclassified by Prudential as punitive damages, but the attorney did not provide any tax advice regarding this item. Prudential, in connection with the settlement and release of the loan obligation, issued petitioner a Form 1099 MISC, Miscellaneous Income, for 1990 reflecting $325,000 as nonemployee compensation to petitioner. Petitioner did not report the settlement as income. During 1987, while petitioner’s dispute with Prudential was ongoing, he transferred his interests in the JAC Ranch and the Newport Beach residence to Mrs. Corrigan. Mrs. Corrigan quit- claimed the deeds for both properties back to petitioner once the Prudential matter was settled. At all pertinent times, petitioner was the sole mortgagee and the only person obligated to make mortgage payments with respect to the mortgage on the JAC Ranch property.Page: 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