Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $14,117.20 in petitioners' Federal income tax for the year 1978.
After concessions by the petitioners, the only issue for decision is whether severance pay of $47,377 received by petitioner Joseph R. Ewers in 1978 is includable in his gross income in its entirety for that year or whether $26,435.23 thereof can be deferred for income tax purposes until 1979...
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