- 2 -
and (2) whether petitioner is entitled to exclude from gross income
amounts paid as legal fees.
Unless otherwise indicated, all section references are to the
Internal Revenue Code as in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated herein
by this reference.
Cheryl Denese Brewer (petitioner) resided in Los Angeles,
California, at the time she filed her petition. At all relevant
times, petitioner was an insurance agent.
On June 1, 1979, a class action lawsuit, Kraszewski v. State
Farm Gen. Ins. Co., was filed against State Farm General Insurance
Co., State Farm Mutual Automobile Insurance Co., State Farm Life
Insurance Co., and State Farm Fire and Casualty Co. (State Farm) in
the U.S. District Court for the Northern District of California.1
The class representatives alleged that State Farm had engaged in
statewide discrimination in California in the recruiting, hiring,
and training of women for sales agent trainee positions in
1 On Sept. 9, 1981, the District Court for the Northern
District of California certified a class in Kraszewski to
maintain the action. See Kraszewski v. State Farm Gen. Ins. Co.,
27 Fair Empl. Prac. Cas. (BNA) 27 (N.D. Cal. 1981).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011