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petitioner’s 1998 Federal income tax. The issues are (1) whether
petitioner may exclude from gross income under section 104(a)(2)
payments received from her former employer pursuant to a
settlement agreement, and (2) whether petitioner is liable for
the accuracy-related penalty under section 6662(a). Petitioner
resided in Evergreen Park, Illinois, at the time the petition was
filed.
Background
Dobbs International Services (Dobbs) hired petitioner in
April of 1993 as a service employee at O’Hare International
Airport. Every October, Dobbs required all employees to “bid”
for job positions with the company. The bidding process was
based on seniority, and Dobbs granted the most senior employees
the right to bid for a job position first. Petitioner alleged
that in October of 1993, a manager at Dobbs granted a male
employee, with less seniority than petitioner, the right to bid
for petitioner’s job position before her. As a result,
petitioner lost her position as service employee, and Dobbs
placed her in an on-call position.
Petitioner filed her first complaint with the Equal
Employment Opportunity Commission (EEOC) on December 8, 1993.
The complaint stated in part:
III. I believe that I have been discriminated against on the
basis of my sex, female, in violation of Title VII of the
1964 Civil Rights Act, in that I was denied the opportunity
to bid on a position for which male employees were allowed
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