On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants,