MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined a $1,710 deficiency in petitioners' 1994 Federal income tax. After concessions, the issue for decision is whether petitioners, pursuant to section 104(a)(2), are entitled to exclude from gross income $8,705.59 in separation payments. We hold that they are not. All section references are to the Internal Revenue Code in effect for the year in issue.
FINDINGS OF FACT
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