CHABOT, Judge:
Respondent determined a deficiency in Federal individual income tax against petitioner for 1975 in the amount of $1,745. By amendment to answer, respondent asserts an increased deficiency in the amount of $18,196.28, for a total deficiency in the amount of $19,941.28.
The issues for decision are as follows:
(1) Whether one-half of the $75,000 payment to petitioner from Muhlenberg College in settlement of litigation is excludable...
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