Citing Kenseth, 114 TC 399 (2000), the guide states that the Tax Court held that anticipatory assignment principles require a taxpayer to include in gross income the entire amount of judgment/settlement proceeds undiminished by any contingent fee, regardless of
the state in which a fee arrangement is signed.
6511 (d) (3) (A), regardless of
whether the taxpayer claimed the FTC under the Code or the treaty.
A taxpayer may deduct daily transportation expenses incurred in commuting between his home office and another work location in the same trade or business, regardless of
whether the work location is regular or temporary and regardless of
If a taxpayer has one or more regular work locations away from his residence, he may deduct daily transportation expenses incurred in going between his residence and a temporary work location in the same trade or business, regardless of
As a result, the Fourth Circuit joined the Eighth and Ninth Circuits in holding that individual taxpayers may not deduct income tax deficiency interest, regardless of
the source of the income.
Note: When relying on the separate rule, care must be exercised when reviewing each reportable cash transfer; the $100,000 threshold appears to apply regardless of
whether earlier cash transfers were reportable transfers.
McKesson "confirmed a long-established and uniform practice of reviewing state-court decisions on federal matters, regardless of
whether the State was the plaintiff or the defendant in the trial court"