- 2 - compensation for a wrongful termination, or a lesser amount that is net of the legal fees and other costs that she incurred to recover this award. We hold it is the greater amount. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. Background All facts have been stipulated.1 The stipulated facts and the exhibits submitted therewith are incorporated herein by this reference. When petitioners petitioned the Court, they resided in Lake Havasu City, Arizona. They are husband and wife, and they filed a 1994 Form 1040, U.S. Individual Income Tax Return, using the filing status of "Married filing joint return". On May 5, 1990, Ms. Coady was discharged from her employment with Alaska Housing Finance Corporation (AHFC). Thereafter, while she resided in Alaska, she retained an attorney in the Alaska office of the law firm of Hellen, Partnow & Condon (HPC) to represent her in a wrongful termination suit against AHFC. According to the terms of that representation: [Ms. Coady is] responsible for all costs incurred, e.g. filing fees, long distance telephone calls, 1 Petitioners ask the Court to find a fact from a letter that they attached to their posttrial brief. We decline to do so. This letter is not evidence. Rule 143(b); see also Boyd Gaming Corp. v. Commissioner, T.C. Memo. 1997-445.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011