United States Ninth Circuit
Polone v. Comm'r of Internal Revenue, 04-72672
A determination of a taxpayer's tax liability for certain years is affirmed where payments he received after the effective date of amendments to 26 U.S.C. section 104(a)(2) based on a defamation settlement agreement executed prior to the effective date of the amendment were taxable as ordinary income. (Substituted opinion)
Appellate Information
- Argued 04/06/2006
- Decided 10/11/2007
- Published 10/11/2007
Judges
- Before: JEROME FARRIS and SIDNEY R. THOMAS, Circuit Judges, and GEORGE SCHIAVELLI, District Judge.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- James M. Harris, Edwin L. Norris, Jonathan M. Brenner, Sidley Austin Brown & Wood LLP, for appellant Gavin Polone.
- For Appellees:
- Bridget M. Rowan, Kenneth L. Greene, Eileen J. O'Connor, United States Department of Justice, for appellee Commissioner of the Internal Revenue Service.