SODOMA v. COMMISSIONER

Docket No. 19881-94.

71 T.C.M. 3178 (1996)

T.C. Memo. 1996-275

Robert C. Sodoma and Gwen A. Sodoma v. Commissioner.

United States Tax Court.

June 13, 1996.


Attorney(s) appearing for the Case

Leonard Lanny Leighton, San Antonio, Tex., for the petitioners.1 Joni D. Larson, for the respondent.


MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $21,104 in petitioners' 1993 Federal income tax.

This case is before us on respondent's motion for summary judgment under Rule 121.2 The issue for consideration is whether petitioners may exclude from gross income, under section 104(a)(2), amounts received from Robert C. Sodoma's employer in consideration for signing a general release and covenant...

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