William Roger and Joan Ann Thorpe - Page 4

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               Petitioner signed the release on July 23, 1992.  Neither at            
          that time nor at any time during the 5 previous years did                   
          petitioner make any complaint or allegation against IBM, either             
          formally or informally, for age discrimination or otherwise.                
          However, petitioner now alleges that he thinks that he has a                
          claim against IBM for age discrimination; petitioner also alleges           
          that IBM is responsible for certain business failures that he               
          suffered after the termination of his employment at IBM.                    
               In exchange for signing the release and participating in the           
          ITO-II Program, petitioner received a $68,279 lump-sum payment              
          (the payment or ITO payment).  The payment was based on years of            
          service and rate of pay.                                                    
               For 1992, petitioner received a Form W-2 from IBM showing              
          wages, tips, and other compensation in the amount of $121,875.03.           
          On October 14, 1993, petitioners filed their 1992 Federal income            
          tax return.  Petitioners reported the $121,875.03 amount on their           
          return as wages.                                                            
               On April 3, 1996, respondent issued a notice of deficiency             
          to petitioners in which respondent determined a deficiency in               
          petitioners' Federal income tax for 1992 in the amount of $1,271.           
          The deficiency is attributable to respondent's disallowance of              
          various deductions claimed on petitioners' 1992 return.                     

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