23 October 2000 Internal T.I. 2000-0027477 F - ALLOCATION DE RETRAITE -- summary under Retiring Allowance

Notwithstanding the position of the TSO that a severance payment was not received by the taxpayer given that he was already engaged in setting up a replacement business where he was employed at the time of receiving the severance, the Directorate found that it was a retiring allowance given that the taxpayer’s employment was terminated.