Wilton Earl and Dorothy M. Keel - Page 2

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            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                          
                  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.                              
                  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                            
                  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                            

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