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as a result of the termination of his employment is excludable from
petitioners’ gross income pursuant to section 104(a)(2).
Unless otherwise indicated, 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
stipulations of facts and attached exhibits are incorporated herein
by this reference.
Background
Petitioners resided in Arlington, Massachusetts, at the time
they filed their petition. They timely filed a joint 1992 income
tax return.
Petitioner was born and raised in Brittany, France. He
studied at the Institute of Chemistry of Paris, Sorbonne
University, receiving a degree in chemical engineering in 1970.
Millipore, S.A. and Millipore Corp.
As of September 22, 1992, petitioner was the corporate vice
president for marketing of Millipore Corp. (Millipore), a Fortune
500 company, and a member of its 12-person executive committee.
Millipore’s business originally was based on the manufacturing
and sale of precise membrane filters capable of removing bacteria
and other harmful particles so as to purify water, air, gas, and
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