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employment agreement |
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TC Memo 2004-45, the Tax Court recently held that a taxpayer's settlement payment to its former chief executive officer (CEO) to terminate an employment agreement and other business-related claims, concurrently with the redemption of the CEO's outstanding shares, was deductible under Sec. In his suit, Fessel said he had a two-year employment agreement with ABC for a $300,000 annual salary, Disney stock options and bonuses, mid $940 per month for an automobile allowance. In connection with Holliday's promotion to CEO, the Company has amended his employment agreement to extend it through January 2010. |
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