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from her income under section 104(a)(2).1 We hold that it is
not; and
2. whether respondent properly determined that $198,000
received by petitioner’s attorney was income to petitioner. We
hold that he did.
FINDINGS OF FACT
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Petitioner resided in Laughlin, Nevada, when this petition was
filed.
Petitioner began working for Whittier Trust Co. (Whittier)
as vice president and director of client administration in
October 1991. After developing symptoms in 1992, petitioner was
diagnosed with active peptic ulcer disease on October 29, 1993.
Petitioner was advised that high stress would exacerbate her
condition, and she therefore requested a 4-day workweek at or
around the end of 1993. Michael Casey (Casey), the president of
Whittier, changed her work schedule to a 4-day workweek as a
reasonable accommodation of her disability (reasonable
accommodation). Casey circulated a company-wide memorandum to
this effect on March 7, 1994.
1 Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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