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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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