- 2 -
in the amounts of $4,446 and $126, respectively. Petitioner
resided in Guthrie, Oklahoma, when she filed her petition in this
case.
The issue is whether $11,100 petitioner received from United
Design Corp. (United) is excludable from gross income under
section 104(a)(2).2
Background
The facts may be summarized as follows. Prior to May 1993,
petitioner worked for the Oklahoma school system. In May 1993,
she was employed by United and became United's personnel manager
in December of that year. Petitioner reported to Robert M.
Clinton, vice president of United. After becoming the personnel
manager conflicts developed between petitioner and other
employees of United. The controversies centered around
petitioner's veracity concerning certain events at United. At
Mr. Clinton's suggestion petitioner was referred to The
University of Oklahoma Health Sciences Center for evaluation.
That evaluation found that petitioner did not appear to be
suffering from brain dysfunction or psychopathology.
However, on June 22, 1994, Mr. Clinton wrote to petitioner
that United had
determined to release you from your at-will employment,
effective this same date. The reasons for this decision
2 Petitioner concedes that, if the $11,100 is includable
in gross income, she is liable for the addition to tax under sec.
6651(a) for failure to timely file her return.
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