- 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 gross
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011