E. Pauline Barnes, (1997)
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E. Pauline Barnes, (1997)
T.C. Memo. 1997-25
UNITED STATES TAX COURT E. PAULINE BARNES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21856-95. Filed January 15, 1997.Kevin D. Watley, for petitioner. C. Glenn McLoughlin, for respondent.MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1992 Federal income tax in the amount of $4,219.After concessions,2 the sole issue for decision is whether section 104(a)(2) authorizes petitioner to exclude from gross income the amount received in settlement of a claim for wrongful termination of employment.Some of the facts have been stipulated and are so found. The stipulations of...See the full content of this document
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