Edward A. and Audrey Primozic, et al . - Page 2




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          petitioners Edward M. and Audrey Primozic, docket No. 26382-96, a           
          $23,352 deficiency for petitioners Thomas J. and Edith M.                   
          Primozic, docket No. 4808-97, and a $50,112 deficiency for                  
          petitioner Kenneth I. Primozic, docket No. 8042-98.  These cases            
          were consolidated for trial, briefing, and opinion pursuant to              
          Rule 141(a).2                                                               
               The sole issue for our consideration is whether payments               
          petitioners received from their former employer are excludable              
          from income as damages received on account of personal injury or            
          sickness under section 104(a)(2).                                           
                                  FINDINGS OF FACT3                                   
               At the time their respective petitions were filed,                     
          petitioners Edward A. Primozic (Edward) and Audrey Primozic,                
          husband and wife, resided in Gaithersburg, Maryland; petitioners            
          Thomas J. Primozic (Thomas) and Edith M. Primozic, husband and              
          wife, resided in Downer’s Grove, Illinois; and petitioner Kenneth           
          I. Primozic (Kenneth) resided in Orland Park, Illinois.  Audrey             
          and Edith Primozic are petitioners in this case solely because              
          they joined in filing Federal income tax returns with their                 



               2 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the year under                      
          consideration, and all Rule references are to this Court’s Rules            
          of Practice and Procedure.                                                  
               3 The stipulation of facts and the attached exhibits are               
          incorporated herein by this reference.                                      




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