At a time that the taxpayer was the dean of a program at a university, the university determined to also permit the taxpayer to become a full-time instructor at the university at a future date. The university terminated his employment, and the taxpayer was then awarded, in an action he brought against the university, nine months' salary and a sum of $90,000 in respect of the breach by the university of its agreement to have the taxpayer become an instructor.
The latter sum was not taxable to the taxpayer as it was not in respect of loss of employment of the taxpayer but was damages for the loss of the future position.