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testimony of Cassandra Nikituk, director of human resources for
Boehringer and one familiar with personnel matters in connection
with the restructuring, also supports that finding. Ms. Nikituk
was the Boehringer official responsible for determining the
amount of the special severance payment that would be offered to
each laid off employee and for authorizing payment of that
amount. She testified that the payment to petitioner was not the
only case in which an offer of a special severance payment to a
laid off employee was extended. Although Ms. Nikituk was not
directly involved in the negotiations with petitioner, she
testified that, at one point, she was asked by a Boehringer
attorney to approve (and she did approve) an additional $2,500 as
“a severance amount to settle this case amicably”. Lastly,
Ms. Nikituk testified that it “was always * * * [her]
understanding” that the payment to petitioner constituted
severance pay.
In Webb v. Commissioner, T.C. Memo. 1996-50, where we
determined that an amount received by an employee leaving the
employ of International Business Machines Corp. (IBM) was
severance pay based on tenure and not damages, we accepted the
dictionary definition of the term “severance pay” as “an
allowance usually based on length of service that is payable to
an employee on termination of employment.” (Citing Webster’s
Ninth Collegiate Dictionary (1985).) That is an appropriate
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