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petitioner's Federal income tax for 1995.
The sole issue for decision is whether certain amounts
received by petitioner from his former employer during 1995 in
connection with the settlement of a class action against his
former employer are excludable from gross income under section
104(a)(2). At trial, the parties conceded certain amounts, and
those concessions are noted hereafter.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner was a
legal resident of Las Vegas, Nevada.
Petitioner was an employee of PayLess Drug Stores Northwest,
Inc. (PayLess), from approximately 1986 to 1993. He started his
employment with PayLess as a temporary employee at Big Spring,
Texas, doing building maintenance. He later was employed by
PayLess on a permanent basis as a shipping and receiving clerk.
After approximately 1 year, he was promoted to supervisor for
approximately 2-3 years, then as a floor manager for 3 years.
After that, petitioner worked approximately 9 months opening new
stores and closing old stores. Following that, PayLess sold its
remaining stores in Texas and Oklahoma, and petitioner was
offered a position with PayLess as a supervisor at Las Vegas,
Nevada, which he accepted. Petitioner's employment with PayLess
terminated in 1993. The record does not reflect the reasons for
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