-2-
petitioners’ concession, we decide whether section 104(a)(2)
excludes from their 2000 gross income $132,000 that petitioner
William L. Kidd (Kidd) received in settlement of the unspecified
“equitable remedy” awarded to him in his reverse discrimination
lawsuit (lawsuit) against the State of California and two of its
agencies (collectively, defendants). We hold it does not.
We also decide whether petitioners are liable for an
accuracy-related penalty under section 6662(a) and (d). We hold
they are not.
FINDINGS OF FACT
Some facts were stipulated. The stipulated facts and the
exhibits submitted therewith are incorporated herein by this
reference. We find the stipulated facts accordingly.
Petitioners, husband and wife, resided in California when their
petition was filed. They filed a joint 2000 Federal income tax
return (2000 return) on August 19, 2001.
In 1985, Kidd and Edward Swiden (Swiden) commenced the
lawsuit in the California Superior Court for Sacramento County
(superior court) by filing a petition for writ of mandamus and
complaint for declaratory and injunctive relief. The defendants
were the State of California (California), the California
Personnel Board (board), and the California Department of Fish
1(...continued)
applicable versions of the Internal Revenue Code.
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