WACHNER v. COMMISSIONER

Docket No. 6291-93.

69 T.C.M. 1982 (1995)

T.C. Memo. 1995-88

Linda J. Wachner v. Commissioner.

United States Tax Court.

Filed March 2, 1995.


Attorney(s) appearing for the Case

Robert A. Jacobs, 1 Chase Manhattan Plaza, New York, N.Y., for the petitioner. Stephen C. Best, John Aletta, and Powell W. Holly, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioner's 1986 Federal income tax in the amount of $820,730. The issue to be decided1 arises out of a settlement of a lawsuit concerning a failed leveraged buyout of a subsidiary of Revlon, Inc. (Revlon). We must decide whether the portion of the settlement proceeds received by petitioner during 1986 is taxable as ordinary income or...

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