MEMORANDUM OPINION
LARO, Judge:
This case is before the Court fully stipulated. See Rule 122. William Joseph and Robin B. Westmiller petitioned the Court to redetermine respondent's determination of a $72,022 deficiency in their 1992 Federal income tax. Following concessions by the parties, the only remaining issue is whether section 104(a)(2) allows petitioners to exclude from their gross income $283,117 of settlement proceeds received from State Farm Insurance...
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