Nathan Putchat and Sally Putchat, Husband and Wife v. Commissioner of Internal Revenue

Third Circuit

Nathan Putchat and Sally Putchat, Husband and Wife v. Commissioner of Internal Revenue

425 F.2d 737

CourtCourt of Appeals for the Third Circuit

DecidedJune 30, 1970

Docket18292

StatusPublished

Cited by7 cases

This text of 425 F.2d 737 (Nathan Putchat and Sally Putchat, Husband and Wife v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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

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Opinion

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 long-term 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.

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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 long-term 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.

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425 F.2d 737, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nathan-putchat-and-sally-putchat-husband-and-wife-v-commissioner-of-ca3-1970.

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