- 2 - received by petitioners from Case Western Reserve University in 1994 is excludable from gross income under section 104(a)(2).2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Shaker Heights, Ohio, at the time they filed their petition. Mr. Reisman was employed by Case Western Reserve University (CWRU) as a tenured full professor of operations research in the Weatherhead School of Management. Mr. Reisman filed a lawsuit in the U.S. District Court, Northern District of Ohio (Federal case), and petitioners filed another lawsuit in the Cuyahoga County Common Pleas Court (State case). Both lawsuits were filed against CWRU and various individuals. The claim asserted in the Federal case involved age discrimination. The claims asserted in the State case involved age discrimination, invasion of privacy, defamation, intentional infliction of emotional distress, and loss of consortium. The Federal case was tried before a jury in February 1993, 1(...continued) $350,000 in dispute is includable in petitioners’ 1994 gross income. 2Unless otherwise indicated, all section references are to 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011