- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011