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per share by September 30, 1994, and to resell to NHP the
necessary number of shares (to pay off the new loan) at $300 per
share. The separation agreement then states that this would
result in “a net aggregate price of $43,200 if all 1,200 shares
are resold.”
By executing the separation agreement, petitioner also
agreed to execute a release and waiver of claims, hereinafter
sometimes referred to as the release agreement. Under the
release agreement, petitioner promised to waive any and all
claims he may have had against NHP whether or not connected with
his employment by NHP. The release agreement recites that
petitioner’s agreements thereunder are in consideration for NHP’s
providing to him “certain payments and other valuable
consideration, to which the Employee [petitioner] is not
otherwise entitled, as set forth in the Separation Agreement.”
Petitioner executed the release agreement on September 20, 1994.
Petitioner’s 1994 tax return includes a Form W-2c, Statement
of Corrected Income and Tax Amounts, from NHP to petitioner,
which provides the information set forth in table 1.
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