- 10 -
same employer and from the ensuing period of underemployment.
Yet, most of this suffering occurred after
petitioner'stermination. Petitioner had made no claims based on
personal injury prior to his signing the Release. The ITO
allowance was not paid on account of any tort-type personal
injuries.
In conclusion, we hold that petitioner's ITO payment is not
excludable from gross income under section 104(a)(2). In keeping
with this holding.
An appropriate
order and decision will be
entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011