Robert C. Sodoma and Gwen A. Sodoma - Page 4

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                    1. The payment and benefits provided pursuant to                  
               the ATP constitute consideration for this release, in                  
               that they are payments and benefits to which you would                 
               not have been entitled had you not signed this release.                
                              *   *   *   *   *   *   *                               
                    3.  This release does not waive any claims that                   
               you may have which arise after the date you sign this                  
               Mr. Sodoma signed the release on September 28, 1993.                   
               In addition to the release, the parties have stipulated that           
          Mr. Sodoma did not have any preexisting claim of age                        
          discrimination, or other unlawful discrimination, against IBM,              
          either formal or informal, written or oral, pending or inchoate,            
          at the time the release was signed.                                         
               Pursuant to the retirement program, and as consideration               
          for the release, Mr. Sodoma received $69,636 from IBM, calculated           
          on the basis of time of service and rate of pay.  IBM reported              
          that amount on Mr. Sodoma's W-2 wage statement.                             
               Except as otherwise provided, gross income includes income             
          from all sources.  Sec. 61(a); Commissioner v. Glenshaw Glass               
          Co., 348 U.S. 426 (1955).  While section 61(a) is to be broadly             
          construed, statutory exclusions from income must be narrowly                
          construed.  Commissioner v. Schleier, 515 U.S.    , 115 S. Ct.              
          2159, 2163 (1995); Kovacs v. Commissioner, 100 T.C. 124, 128                
          (1993), affd. without published opinion 25 F.3d 1048 (6th Cir.              

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