-3-
1990 tax returns (Form 1040X) to respondent's counsel on August 26,
1995, which was approximately 10 days prior to trial.
In January 1987, Mr. Martin accepted employment with Woodhead
Industries, Inc. (Woodhead), as president of Aero-Motive Co. (Aero-
Motive), a subsidiary of Woodhead. As such, Mr. Martin was
responsible for overseeing a 250-person, $25 million manufacturing
plant in Kalamazoo, Michigan. He was hired to "do a turnaround and
save the company." Prior to accepting employment with Woodhead,
Mr. Martin worked for Allen Bradley Co. in Cleveland, Ohio.
Mr. Martin was relieved of his duties as president of Aero-
Motive on September 20, 1989; he remained in Woodhead's employ, as
a consultant, until June 8, 1990. As part of Mr. Martin's
severance package, Woodhead agreed to continue paying Mr. Martin
from June 8, 1990, until September 7, 1990, in the event he found
no other employment during that period of time.
Moving Expenses
In January 1987, Mr. Martin moved from Cleveland to Kalamazoo,
living in an apartment made available to him by Woodhead (the
company apartment). Mrs. Martin joined her husband in Kalamazoo
following the sale of their house in Cleveland in April or May of
1987. Because Mrs. Martin brought the family pets (a dog and a
cat) with her to Kalamazoo, petitioners were required to move from
the company apartment to another apartment. The furniture and
personal belongings of the Martins were shipped from Cleveland to
Kalamazoo at the time Mrs. Martin joined her husband; most of the
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