HOYT, Judge:
The respondent determined a deficiency in petitioner's income tax for the calendar year 1959 in the amount of $387,990.58. The sole issue for decision is whether an amount of $800,000 recovered by petitioner in partial settlement of a litigation claim in 1959 must be included in taxable income.
FINDINGS OF FACT
Most of the facts have been stipulated. The stipulation of facts, supplemental stipulation of facts, and attached exhibits...
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