- 8 - [the Meadowlands]” in exchange for: (1) Payments totaling $225,000; and (2) his resignation as an employee of the Meadowlands. The settlement agreement also states that the Meadowlands and petitioner were entering into the settlement agreement to avoid the costs of litigation. In the settlement agreement, Meadowlands expressly denies any liability with respect to the claims alleged by petitioner. The settlement agreement makes no reference to a physical injury or physical sickness resulting from the Meadowlands’ actions, nor does the settlement agreement specifically carve out any portion of the settlement payment as a settlement on account of personal physical injury or physical sickness. Petitioner officially terminated his employment with the Meadowlands on September 9, 1999. During 1999, petitioner received settlement proceeds of $199,073 from the Meadowlands (the settlement proceeds). As previously noted, petitioners filed a timely joint 1999 Federal income tax return. The income reported on that return includes the settlement proceeds. On April 23, 2001, petitioners submitted a Form 1040X, Amended U.S. Individual Income Tax Return, for the 1999 taxable year. On the 1999 amended return petitioners excluded the settlement proceeds from their grossPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011