Scribd Logo
Upload

Welcome to Scribd!

  • Nathan Putchat and Sally Putchat, Husband and Wife v. Commissioner of Internal Revenue, 425 F.2d 737, 3rd Cir. (1970)

    Uploaded by

    Scribd Government Docs
    8 views2 pages
    The document is a court case summary from the United States Court of Appeals for the Third Circuit. It affirms the decision of the Tax Court, which held that $75,000 received in settlement of a lawsuit to enforce contract rights constituted ordinary income rather than long-term capital gain for Nathan and Sally Putchat. The Court of Appeals reviewed the record and contentions of counsel and found the Tax Court correctly decided the issues of fact and law in the case.

    Original Description:

    Filed: 1970-06-30 Precedential Status: Precedential Citations: 425 F.2d 737 Docket: 18292

    Copyright

    © Public Domain

    Available Formats

    PDF or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    The document is a court case summary from the United States Court of Appeals for the Third Circuit. It affirms the decision of the Tax Court, which held that $75,000 received in settlement of a lawsuit to enforce contract rights constituted ordinary income rather than long-term capital gain for Nathan and Sally Putchat. The Court of Appeals reviewed the record and contentions of counsel and found the Tax Court correctly decided the issues of fact and law in the case.

    Copyright:

    Public Domain
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    Download as pdf
    8 views2 pages

    Nathan Putchat and Sally Putchat, Husband and Wife v. Commissioner of Internal Revenue, 425 F.2d 737, 3rd Cir. (1970)

    Uploaded by

    Scribd Government Docs
    The document is a court case summary from the United States Court of Appeals for the Third Circuit. It affirms the decision of the Tax Court, which held that $75,000 received in settlement of a lawsuit to enforce contract rights constituted ordinary income rather than long-term capital gain for Nathan and Sally Putchat. The Court of Appeals reviewed the record and contentions of counsel and found the Tax Court correctly decided the issues of fact and law in the case.

    Copyright:

    Public Domain
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    Download as pdf
    of 2

    425 F.

    2d 737

    Nathan PUTCHAT and Sally Putchat, husband and wife,


    Appellants,
    v.
    COMMISSIONER OF INTERNAL REVENUE.
    No. 18292.

    United States Court of Appeals, Third Circuit.


    Argued April 9, 1970.
    Decided May 4, 1970.
    Rehearing Denied June 30, 1970.

    Arthur Pelikow, New York City, (Robert B. Alexander, Jr., Stuart M.


    Berkman, New York City, on the brief), for appellants.
    William S. Eastabrook, Dept. of Justice, Tax Division, Washington, D. C.
    (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Thomas L.
    Stapleton, Janet R. Spragens, Attys., Dept. of Justice, Washington, D. C.,
    on the brief), for appellee.
    Before SEITZ and ALDISERT, Circuit Judges, and LATCHUM, District
    Judge.
    OPINION OF THE COURT
    PER CURIAM.

    Nathan and Sally Putchat filed a joint federal income tax return for 1959. The
    Commissioner subsequently determined that they improperly reported as longterm capital gain $75,000.00 received in complete settlement of a lawsuit by
    Nathan seeking to enforce his rights under a contract. Taxpayers petitioned the
    Tax Court for a redetermination of the deficiency. The court rejected their
    petition, holding that "an amount received by petitioner as consideration for the
    release of all his rights under an employment contract * * * constitutes ordinary
    income." 52 T.C. 470 (1969). This appeal followed.
    We have reviewed the record made below in the light of the contentions of

    counsel both in their briefs and at oral argument. We are convinced that the Tax
    Court correctly decided the issues of fact and law and therefore affirm on its
    opinion.
    The judgment of the Tax Court will be affirmed.

    You might also like