RAYTHEON PRODUCTION CORPORATION V. COMMISSIONER
144 F.2d 110, cert denied 323 U.S. 779 (1944)
NATURE OF THE CASE: This was a dispute over the tax status of a damages award. Raytheon
(P) appealed a Tax Court holding that an amount received in settlement of federal antitrust
suit for damages was taxable income.
FACTS: Raytheon filed a suit and alleged that the illegal conduct of R.C.A. completely
destroyed the profitable interstate and foreign commerce of its tube business. Raytheon
alleged that by 1928, its business with a value in excess of three million dollars was now
worthless. The allegations and evidence of the amount of profits was used to establish good
will and a method on which to recover a return of capital. The suit was ended in a
compromise settlement. The IRS got involved and said that this settlement was taxable as
income. Raytheon disagreed and appealed that decision.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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