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WISE v. COMMISSIONER

Docket No. 6344-96.

75 T.C.M. 1514 (1998)

T.C. Memo. 1998-4

John R. and Sara E. Wise v. Commissioner.

United States Tax Court.

Filed January 5, 1998.

Attorney(s) appearing for the Case

John A. Mase, Los Angeles, Calif., Howard S. Hou, and Mark A. Byrne, for the petitioners. Mark A. Weiner, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $283,425 deficiency in petitioners' 1989 Federal income tax. The sole issue for decision is whether $1,012,233 received by John R. Wise as a result of the termination of his employment is excludable from petitioners' 1989 gross income pursuant to section 104(a)(2) as damages received on account of personal injury or sickness....

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