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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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