- 19 -
voluntarily or involuntarily in 1991 (or, in one case, 1992) and
received the Termination Award and SRP Cashout under the 1990
Employment Agreements. Petitioner treated these payments as
parachute payments for purposes of section 280G. The remaining
11 senior executives who were parties to the 1990 Employment
Agreements (Retained Executives) entered into new employment
agreements with petitioner on November 14, 1991 (1991 Employment
Agreements), covering their services after that date, which
replaced the 1990 Employment Agreements.11 The 1991 Employment
Agreements are described more fully hereinafter. The Retained
Executives and their pre- and post-control-change titles were as
follows:
11 Two Retained Executives did not execute their 1991
Employment Agreements until early 1992.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011