Income Tax Keyed to Lind
Sinyard v. Commissioner
James Sinyard was the division manager of IDS Financial Services in Mobile, Alabama. He was allegedly forced to resign in 1987 at the age of 49. He joined two class action suits against IDS alleging age discrimination. His agreement with the law firm provided that the firm would be paid one-third of any recovery. The suits were settled in 1990 and IDS agreed to pay $35 million in settlement of all claims. The 32 plaintiffs allocated one-third to attorneys’ fees. IDS paid the attorneys’ fees directly to the law firm. The Commissioner of Internal Revenue assessed a deficiency on Sinyard claiming that the $252,608 in attorneys’ fees should be treated as income to Sinyard. The Tax Court affirmed the Commissioner.
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