Lubart v. Commissioner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that lump sum payment intended to compensate for lost wages upon early retirement rather than to settle personal injury claims was severance payment
• concluding that lump sum payment intended to compensate for lost wages upon early retirement rather than to settle personal injury claims was severance payment
• concluding that Lubart’s termination agreement, executed as part of a broad IBM downsizing program, “was a standard document offered to all employees” and its amount was calculated based on salary and years of service
• “If section 104(a)(2) were construed to encompass releases of potential unspecified future claims, ... manufacturing section 104(a)(2) tax treatment would be simple.”
• “[T]he intent of the under $332,000—well over six times the standard amount. employer [] determine[s] the treatment of the payment.”
• “[T]he intent of the employer [ ] determine^] the treatment of the payment.”

Source: CourtListener parenthetical corpus (CC0).