- 2 - 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 yearPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011