DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year 1959 in the amount of $10,044.91.
The only issue for decision is whether the amount of $45,000 received by petitioner Hubert M. Luna (hereafter sometimes referred to as petitioner) from Pioneer Life & Casualty Co., Inc. (hereafter referred to as Pioneer), in 1959 as consideration for the release of rights to which petitioner was entitled under a contract...
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