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FOOTE v. COMMISSIONER

Docket No. 9667-81.

81 T.C. 930 (1983)

MERRILL J. FOOTE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 7, 1983.

Attorney(s) appearing for the Case

Merrill J. Foote, pro se.

Gary A. Benford, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for the years 1977 and 1978 in the amounts of $2,715 and $4,074, respectively. The primary issue is whether money paid to petitioner pursuant to his resignation of his tenured faculty position at Southern Methodist University is taxable as ordinary income or as long-term capital gain. Petitioner also argues that the Court erred in...

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