- 2 - of his employment relationship with Holnam, Inc., is excludable under section 104(a)(2)2 as damages received on account of personal injury or sickness.3 FINDINGS OF FACT Petitioners resided in Cheyenne, Wyoming, at the time their petition was filed. In 1975, petitioner, who had obtained a college degree in engineering, began employment with Ideal Cement Industries. Holnam, Inc. (Holnam), became the successor to Ideal Cement Industries. In 1985, petitioner was selected to go to Montana to manage a plant that had not performed well. By 1990, the plant’s performance had improved. As of 1993, petitioner had been promoted to regional sales manager for Montana, and his office was located in Bozeman, Montana. During 1993, Holnam announced a reorganization of the sales portion of its organization, and petitioner's position was to be eliminated. Although the Bozeman office was to remain open and a position higher than petitioner’s was to continue, the higher level position in Bozeman was offered to a Holnam employee from 1(...continued) joint return with Darrell D. Moran, who will be referred to as petitioner in this opinion. 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the period under consideration, and all Rule references are to this Court’s Rules of Practice and Procedure. 3 Two other adjustments were set forth in the notice of deficiency, both of which were computational and dependent on the outcome of the question of excludability of the $37,840 amount.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011