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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
Procedure.
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Last modified: May 25, 2011