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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner filed a timely 1995 Federal income tax return. At the
time the petition was filed, he resided in Bedminster, New
Jersey.
Petitioner began employment with AT&T Communications, Inc.
(AT&T) in December 1963 and remained so employed until his
employment was terminated, as discussed below, on May 18, 1995.
As of that date, and during all other times relevant here, he was
a manager in AT&T’s international operations division. As a
manager, petitioner’s employment relationship with AT&T was
described as “at-will”, which, according to an AT&T publication,
meant that petitioner had “the right to terminate * * * [his]
employment at any time for any reason, and * * * [AT&T reserved]
the right to terminate * * * [petitioner] on the same basis,
regardless of any statements, written or oral, by * * * [AT&T],
or any of its employees or representatives, which may seem to be
the contrary.”
In early 1994, petitioner received formal notification that
senior managers within his division had elected to implement
AT&T’s Force Management Program (the retirement program). He was
57 years old at the time. As described in literature provided to
petitioner by AT&T, the retirement program was designed “to give
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