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Portion of Settlement in Personal Injury Case Allocated to Taxable Prejudgment Interest: Rozpad v. Commissioner

In Rozpad v. Commissioner, the First Circuit held that when a settlement in a personal injury case, entered into following a judgment in the case, contains no allocation of damages and prejudgment interest, the Service may allocate a portion of the settlement to interest. The ratio between damages and interest in the prior (although not final) judgment is the proper basis for the Service's allocation. ...

Rebecca S. Briggs

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