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BAGLEY v. COMMISSIONER

Docket No. 531-93.

105 T.C. 396 (1995)

HUGHES A. BAGLEY AND MARILYN B. BAGLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 11, 1995.

Attorney(s) appearing for the Case

Mark Arth, for petitioners.

Jack Forsberg, for respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1987 in the amount of $488,976.31. The issues for decision are: (1) What portion, if any, of the amount of $1.5 million paid to Hughes Bagley (petitioner) in settlement of a suit against Iowa Beef Processors, Inc. (IBP), is allocable to punitive damages; (2) whether the $500,000 in punitive damages paid to petitioner pursuant to a judgment against IBP, and the...

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