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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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Last modified: May 25, 2011