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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.
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