Burns v. Commissioner
United States Court of Appeals for the Ninth Circuit
325 F. App’x 596 (2009)
- Written by Abby Roughton, JD
Facts
Sara Burns (plaintiff) received a whistleblower reward that was paid to her in installments by the United States government. Burns was a debtor in a bankruptcy proceeding, and the bankruptcy court ordered that the final reward installment be paid to Burns’s attorney’s client trust account pending the resolution of a creditor’s claim against Burns in the bankruptcy. Burns excluded the amount of the final installment from her federal income-tax return, asserting that she did not actually or constructively receive the money because it had been deposited into her attorney’s account. The Commissioner of Internal Revenue (defendant) determined that the funds were includible in Burns’s tax return, and the United States Tax Court agreed. Burns appealed the tax court’s judgment.
Rule of Law
Issue
Holding and Reasoning ()
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