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Corporation (IBM) is excludable from petitioners' 1993 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.
Petitioners resided in New Canaan, Connecticut, at the time
they filed their petition.
Petitioner was born on April 23, 1938. He graduated from Yale
Law School in 1964, and subsequently became a member of the New
York and District of Columbia bars. Margaret Sherman, petitioner's
wife, did not work outside the home.
Employment with IBM
Petitioner was employed by IBM between December 1, 1965, and
May 28, 1993. At all relevant times, he was a staff attorney,
assigned to the IBM corporate division.
The IBM corporate division determined that "permanent resource
reductions" (permanent employee layoffs) were necessary. This
determination was announced sometime in February 1993.
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