- 2 - 104(a)(2)1 amounts received from petitioner Dorothy M. Keel's employer upon termination of her employment on the ground that such amounts represented damages received on account of personal injury. This case was submitted fully stipulated under Rule 122. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Beltsville, Maryland, at the time they filed their petition. Background Petitioner Dorothy M. Keel (Mrs. Keel) was employed by International Business Machines Corporation (IBM) until her termination in 1992. In 1992, IBM terminated thousands of its employees pursuant to a corporate restructuring plan. Mrs. Keel received a lump-sum payment of $40,411.21 from IBM in 1992 (the lump-sum payment) in connection with her termination. The amount of the lump-sum payment was based on length of her service and salary. On June 15, 1992, Mrs. Keel signed a General Release and Covenant Not to Sue (the release) as a condition for the sums and benefits, including the lump-sum payment, she received pursuant to the terms of the Modified and Extended Individual Transition 1 Unless otherwise indicated, all statutory 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011