John R. and Sara E. Wise - Page 2

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          gross income pursuant to section 104(a)(2) as damages received on           
          account of personal injury or sickness.                                     
               All section references are to the Internal Revenue Code as in          
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
               John R. and Sara E. Wise resided in Northridge, California, at         
          the time the petition was filed. John R. Wise (petitioner) was born         
          on October 20, 1940.                                                        
          Weyerhaeuser Co.                                                            
               In 1968, petitioner began working for Weyerhaeuser Co. (WC) as         
          a loan officer.  WC is in the home-building and mortgage business.          
          Petitioner later worked for Weyerhaeuser Mortgage Co. (WMC), a WC           
          subsidiary.  Petitioner rose through the ranks at WMC, and by the           
          late 1980's he became its president and chief executive officer.            
          At that time, WMC was the third or fourth largest mortgage company          
          in the United States.                                                       
               Petitioner also served in the late 1980's as chief executive           
          officer of Republic Federal Savings and Loan (RFSL), another WC             
          subsidiary, and as chairman of the board of directors of Mortgage           
          Investments Plus (MIP), a publicly owned real estate investment             

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