Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated February 27, 1986, determined a deficiency in petitioner's and her husband's joint 1979 income taxes of $124,399.04. After concessions, including those made on brief, we must determine: (1) Whether any part of certain settlement proceeds petitioner and her husband received are excludable under section 104(a)(2);
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