John Lee Berst & Carolyn Ann Pace, a.k.a. Carolyn Ann Berst - Page 2

                                                  -2-                                                   
            made by State Farm Insurance Company to petitioner Carolyn Ann                              
            Berst to encourage her to settle her sex discrimination claim in                            
            a class action suit brought under Title VII of the Civil Rights                             
            Act of 1964, 42 U.S.C. sec. 2000e et seq.   The facts have been                             
            stipulated.  Unless otherwise indicated, all section references                             
            are to the Internal Revenue Code in effect for the year in issue,                           
            and all Rule references are to the Tax Court Rules of Practice                              
            and Procedure.                                                                              
                  Petitioners, husband and wife, are John Lee Berst and                                 
            Carolyn Ann Pace, a.k.a. Carolyn Ann Berst.  References to                                  
            petitioner in the singular will be to petitioner wife.  When the                            
            petition in this case was filed, petitioners resided in Truckee,                            
            California.                                                                                 
                  Petitioner was a claimant in the class action litigation                              
            filed on June 1, 1979 in the District Court for the Northern                                
            District of California entitled Kraszewski v. State Farm Gen.                               
            Ins. Co..  On April 29, 1985, the District Court issued Findings                            
            of Fact and Conclusions of Law, and ruled that State Farm was                               
            liable for gender discrimination.  38 Fair Emp. Prac. (BNA) Cas.                            
            197 (N.D. Cal. 1985)  The next year, the District Court issued an                           
            order requiring hearings to determine individual liability and                              
            damages.  Kraszewski v. State Farm Gen. Ins. Co., 41 Fair Empl.                             
            Prac. (BNA) Cas. 1088 (N.D. Cal. 1986)   Following the order, the                           
            litigants reached agreements with respect to all issues                                     
            concerning the distribution of monetary relief.  These agreements                           




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