Court of Appeals for the Third Circuit April 3, 1990, 19-1969 (Frank E. & Mildred E. Rickel v. Commissioner of Internal Revenue)

OPINION OF THE COURT

COWEN, Circuit Judge.

The appellant Frank E. Rickel (“the taxpayer”)

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received $80,000 from his former employer in 1983 and $25,000 in 1984 pursuant to a settlement of his Age Discrimination in Employment Act (“ADEA”) lawsuit. This appeal requires us to decide whether the United States Tax Court properly determined that one-half of this settlement represented taxable income.