- 2 -
352, 78 Stat. 241 (title VII), is excludable from gross income
under section 104(a)(2); and (2) if the title VII proceeds are
includable in income, whether petitioner is entitled to exclude
from gross income that portion of the proceeds paid as attorney’s
fees under her contingent fee retainer agreement.
FINDINGS OF FACT1
The facts in this case have been fully stipulated, and the
case was submitted to the Court under Rule 122.2 Petitioner
resided in Shawnee, Kansas, at the time her petition was filed in
this case.
Petitioner was employed at the International Union of
Operating Engineers, Hoisting and Portable Local No. 101 (Local
101) from July 10, 1978, to October 29, 1984. On May 23, 1990,
petitioner filed a Complaint in the U.S. District Court for the
Western District of Missouri, Western Division, against Local 101
and against Sam F. Long (Long), the Chief Executive Officer of
Local 101 during petitioner’s employment. Petitioner’s Complaint
contained the allegation that, in 1984, she was constructively
discharged in violation of title VII. Petitioner sought
1 The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
2 Unless otherwise indicated, Rule references are to this
Court’s Rules of Practice and Procedure, and section references
are to the Internal Revenue Code in effect for the taxable year
in question.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011