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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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