BYRNE v. COMMISSIONER

Docket No. 38959-84.

90 T.C. 1000 (1988)

CHRISTINE A. BYRNE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 1988.


Attorney(s) appearing for the Case

Mary F. Thurber, for the petitioner.

Frank Agostino, for the respondent.


OPINION

RAUM, Judge:

The Commissioner determined a deficiency in petitioner's 1981 income tax in the amount of $5,561. The issue before us is the excludability from petitioner's income under section 104(a)(2), I.R.C. 1954, of amounts she received from her former employer.1 The case was submitted on the basis of a stipulation of facts and attached exhibits. At the time the petition herein was filed, petitioner resided in...

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