- 2 -
Respondent determined a deficiency in petitioners’ Federal
income tax of $2,184 for the taxable year 1997.
The issue for decision is whether petitioners are entitled
under section 104(a) to exclude from income an amount received
pursuant to a severance package.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Muskego, Wisconsin, on the date the petition was filed in this
case.
Petitioner husband (petitioner) was employed as an
application systems engineer with Amdahl Corporation from 1994 to
1997. Petitioner was treated in 1994 through 1996 for carpal
tunnel syndrome (CTS), the symptoms of which had begun prior to
his employment at Amdahl. Petitioner’s treatment included
surgery which caused him to miss work for 1 week and 5 days in
1994 and for 3 weeks and 4 days in 1995. He received payments
from an insurance company on behalf of Amdahl for the treatment
of CTS and for lost wages. The insurance company questioned
responsibility for the payment of the expenses due to the fact
that petitioner was injured to some extent prior to his
employment at Amdahl. As of July 17, 1995, petitioner’s medical
records indicate that he no longer had symptoms of CTS and that
there was no permanent disability relating thereto. Petitioner
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011