Nancy J. Vincent, (2005)
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Nancy J. Vincent, (2005)
T.C. Memo. 2005-95
UNITED STATES TAX COURT NANCY J. VINCENT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13470-03. Filed May 3, 2005.John F. Sherwood, Sr., for petitioner. Jean Song, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Respondent determined a $161,940 deficiency in petitioner's 1998 income tax. Following trial of this matter, we must decide as to 1998: 1. Whether $240,000 received by petitioner in settlement of an employment discrimination lawsuit (lawsuit) is excludable 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 diagnos...See the full content of this document
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