Marsha M. Bland - Page 2




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                  Kevin Burke and Leonard Leighton, for petitioner.                                    
                  Elizabeth A. Owen, for respondent.                                                   


                                        MEMORANDUM OPINION                                             

                  NIMS, Judge:  Respondent determined a Federal income tax                             
            deficiency for petitioner’s 1994 taxable year in the amount of                             
            $13,816.  Respondent also determined an accuracy-related penalty                           
            of $2,765 for 1994, pursuant to section 6662(a).  After                                    
            concessions, the sole issue for decision is whether a $58,845                              
            payment received by petitioner from her employer, in connection                            
            with the termination of her employment, is excluded from income                            
            under section 104(a)(2).                                                                   
                  Unless otherwise indicated, all section references are to                            
            sections of the Internal Revenue Code in effect for the year in                            
            issue, and all Rule references are to the Tax Court Rules of                               
            Practice and Procedure.                                                                    
                  This case was submitted fully stipulated pursuant to Rule                            
            122.  The stipulations of the parties, with accompanying                                   
            exhibits, are incorporated herein by this reference.                                       
                                             Background                                                
                  Marsha M. Bland resided in Las Vegas, Nevada, at the time of                         
            filing her petition in this case.  Prior to and during the year                            









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