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MEMORANDUM OPINION
HALPERN, Judge: Respondent determined a deficiency of
$30,993 in petitioner’s 1993 Federal income tax. The only issue
to be decided is whether petitioner may exclude from gross income
any portion of a payment received pursuant to a settlement
agreement in 1993.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for 1993, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference. We need find few facts in addition to
those stipulated and, accordingly, will not separately set forth
those findings. We will include additional findings of fact in
the discussion that follows. Petitioner bears the burden of
proof on all questions of facts. Rule 142(a).
Background
At the time the petition was filed, petitioner resided in
Monroe, New York.
Petitioner was born in 1946 and reached the age of 47 in
1993.
Petitioner was employed as an attorney with Boehringer
Ingelheim Pharmaceutical, Inc. (Boehringer), from October 1,
1979, through May 11, 1992.
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