MEMORANDUM OPINION
HALPERN, Judge:
Respondent determined a deficiency of $30,993 in petitioner's 1993 Federal income tax. The only issue to be decided is whether petitioner may exclude from gross income any portion of a payment received pursuant to a settlement agreement in 1993.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect for 1993, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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