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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1992. References to
petitioner are to James T. Sinyard.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Scottsdale, Arizona.
In 1989, petitioner joined two class action lawsuits pending
in the U.S. District Court for the District of Minnesota (namely,
Glass v. IDS Fin. Servs., Inc., Civ. No. 4-89-76 (Glass), and
Stephens v. IDS Fin. Servs., Inc., Civ. No. 4-89-115 (Stephens).
The law firm of Winthrop and Weinstine represented the class
plaintiffs.
In the original and amended complaints in Glass and in
Stephens, it was alleged that IDS Financial Services, Inc., IDS
Life Insurance Co., and IDS Financial Corp. (IDS): (1) Engaged
in a pattern and practice of age discrimination against older
division managers employed by IDS in violation of the Age
Discrimination in Employment Act of 1967 (ADEA), Pub. L. 90-202,
81 Stat. 602, the Employee Retirement Income Security Act of 1974
(ERISA), Pub. L. 93-406, 88 Stat. 829, and State law; (2) imposed
illegal chargebacks against its division managers; and (3)
intentionally inflicted emotional distress on certain of its
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