T.C. Memo. 1999-202
UNITED STATES TAX COURT
RICHARD AND MARGARET SHERMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11665-97. Filed June 18, 1999.
Richard Sherman, pro se.
Margaret Sherman, pro se.
Jack H. Klinghoffer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $70,120 deficiency in
petitioners' 1993 Federal income tax. The sole issue for decision
is whether the $207,000 Richard Sherman (petitioner) received upon
termination of his employment with International Business Machines
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