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BRITELL v. COMMISSIONER

Docket No. 26958-93.

69 T.C.M. 2904 (1995)

T.C. Memo. 1995-264

Jenne K. Britell v. Commissioner.

United States Tax Court.

Filed June 15, 1995.

Attorney(s) appearing for the Case

Daniel Jacobson and Steven P. Kaplan, New York, N.Y., for the petitioner. Craig Connell, for the respondent.

Memorandum Findings of Fact and Opinion

LARO, Judge:

Jenne K. Britell petitioned the Court to redetermine respondent's determination of a $32,415.92 deficiency in her 1990 Federal income tax and a $6,483.19 addition thereto under section 6662(a). Following respondent's concession of the addition to tax, we must decide whether a $102,288.48 payment received by petitioner from her former employer is excludable from her gross income under section 104(a)(2)...

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