- 2 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011