United States Third Circuit

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DeNaples v. Comm'r of Internal Revenue, 11-2205

In a case involving a settlement under which Pennsylvania agreed to pay landowners for a taking in five yearly installments, a Tax Court order upholding a federal income tax deficiency notice issued to the landowners is: 1) reversed in part, where the Tax Court erred as a matter of law when it held that the taxpayers should have included interest they received on the installment payments in their gross income calculation; and 2) affirmed in part, where the Tax Court did not err it holding that none of the settlement interest was excludable from income, as the taxpayers failed to meet their burden of proof that the deficiency was inaccurate.

Appellate Information

  • Decided 03/19/2012
  • Published 03/19/2012


  • Fuentes


  • United States Third Circuit


  • For Appellant:
  • Alan I. Horowitz, Randolph L. Hutter

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