James J. and Linda J. Harford - Page 2

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               The sole issue for decision is whether $24,060.44 received             
          by James J. Harford (petitioner husband) as a result of the                 
          termination of his employment is excludable from petitioners'               
          1994 gross income, pursuant to section 104(a)(2), as damages                
          received on account of personal injury or sickness.                         
          Some of the facts were stipulated, and those facts, with the                
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioners'                
          legal residence was Durham, North Carolina.                                 
               Petitioner husband received a bachelor of science degree in            
          electrical engineering from Georgia Tech University in 1984.                
          That same year petitioner husband became employed by                        
          International Business Machines Corp. (IBM) in the company's                
          Kingston, New York, facility.  In 1987, petitioner husband moved            
          to the Raleigh-Durham area of North Carolina and remained                   
          employed with IBM.  Following his move to North Carolina, and               
          concurrent with his continued employment with IBM, petitioner               
          husband pursued and received a master's degree in computer                  
          science from the University of North Carolina.                              
               During May 1994, the manager of petitioner husband's                   
          division at IBM (manager) became concerned about the delay in               
          completing a development project that petitioner husband's                  
          division was working on.  Consequently, the manager advised                 
          petitioner husband and the other members of his division that all           





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