NCA Argyle LP v. Commissioner, T.C. Memo 2020-56 (2020)

NCA Argyle LP v. Commissioner, T.C. Memo 2020-56 (2020). The IRS sought over $5 million in tax, penalty, and interest. In a complete taxpayer victory, the Tax Court held that a $23 million lump-sum payment of settlement proceeds to resolve a joint venture dispute between two partners resulted in capital gains and not ordinary income. 

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