- 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 allPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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