Polone v. CIR, 473 F.3d 1019 (9th Cir. 2007)
Gavin Polone sued his former employer, United Talent Agency, alleging, among other things, wrongful termination and defamation. In settlement of the defamation claim, Polone agreed to accept $4 million in four equal, six-month installments, beginning on May 3, 1996. Congress amended Section 104 of the Internal Revenue Code in August 1996 (after the first but