Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a deficiency of $40,725 in petitioners' Federal income tax for 1986.
After concessions, the sole issue to be decided is whether any part of $56,818, which petitioner received in settlement of his claims against Plumbmaster, Inc., is excluded from taxable income under section 104(a)(2). Respondent concedes that an additional $50,000 that petitioners received is excluded....
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