Ferdinand A. & Marla Morabito, et al. - Page 2

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               Petitioners                           Deficiency                       
               Ferdinand A. and Marla Morabito    $19,462                             
               Joseph J. Chiffone                 13,982                              
               Douglas R. and Joan A. Gamble      30,288                              
               William J. and Roberta E. Prechtl  21,248                              
          This matter is before the Court on Respondent's Motions for                 
          Summary Judgment pursuant to Rule 121.2  In each case,                      
          petitioners submitted in opposition a so-called "Petitioner's               
          Opposition Motion", which was filed simply as "Petitioner's                 
          Opposition".  The cases were consolidated, and each presents the            
          same issue.  That is, whether an amount paid to an employee of              
          IBM upon his severance therefrom conditioned upon his signing of            
          a release relinquishing all existing claims against IBM is                  
          excludable from income under section 104(a)(2).                             
               Petitioners are Ferdinand A. and Marla Morabito, Joseph J.             
          Chiffone, Douglas R. and Joan A. Gamble, and William J. and                 
          Roberta E. Prechtl.  Petitioners lived in Hicksville, NY,                   
          Holbrook, NY, Locust Valley, NY, and Holtsville, NY,                        
          respectively, when their petitions in these cases were filed.               
          References to petitioners will be to the male petitioners.                  
               Prior to and during a portion of 1992, petitioners were                
          employees of IBM.  In 1992, they each signed a document entitled            

          2  Unless otherwise indicated, all section 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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