T.C. Memo. 1998-4
UNITED STATES TAX COURT
JOHN R. AND SARA E. WISE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6344-96. Filed January 5, 1998.
John A. Mase, Howard S. Hou, and Mark A. Byrne, for
petitioners.
Mark A. Weiner, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $283,425 deficiency in
petitioners' 1989 Federal income tax. The sole issue for decision
is whether $1,012,233 received by John R. Wise as a result of the
termination of his employment is excludable from petitioners' 1989
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