PRADO, Circuit Judge:
At issue in this appeal is whether a $50,000 lump-sum payment to "resolve and settle all differences, disputes, and controversies between the parties" in an action concerning various employment-related claims was excludable from a taxpayer's income under Internal Revenue Code § 104(a)(2). The Tax Court held that the taxpayer, Petitioner-Appellant Isidra Elizabeth Espinoza, had not met her burden of establishing that the payor, the Texas...
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