MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $191,580 deficiency in petitioners' 1992 Federal income tax. The sole issue for decision is whether the $600,000 Alain Massot (petitioner) received in 1992 as a result of the termination of his employment is excludable from petitioners' gross income pursuant to section 104(a)(2).
Unless otherwise indicated, all section references are to the Internal Revenue Code as in...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.