Stephen William Dahlgreen - Page 2

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          decision is whether $20,000 paid to petitioner in 1990 by his               
          former employer is excludable from gross income under section               
          104(a)(2).  The resolution of this issue depends upon whether               
          petitioner's former employer intended the payment to compensate             
          him for personal injury arising from a tort or tort type claim.             
          Undisputed Factual Background                                               
               Some of the facts have been stipulated, and they are so                
          found.  At the time the petition was filed, petitioner resided in           
          Springfield, Missouri.                                                      
               In June 1989, petitioner, an attorney who apparently did not           
          practice law during the year in issue, was hired as the vice                
          president of institutional marketing and sales for Comprehensive            
          Marketing Systems, Inc. (CMS).  During the relevant periods CMS             
          specialized in subservicing poorly performing loans for other               
          financial institutions.  During 1990, CMS earned gross receipts             
          totaling approximately $12 million from 8 to 10 different loan              
          servicing contracts.                                                        
               Petitioner was hired by James Griffin, the president and               
          sole shareholder of CMS, to develop a plan to market loan                   
          servicing to financial institutions in the mortgage lending and             
          servicing business.  CMS anticipated that petitioner's sales and            
          marketing plan would generate revenues through the acquisition of           
          additional loan servicing contracts.                                        







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