MEMORANDUM OPINION
LARO, Judge:
This case is before the Court fully stipulated. See Rule 122. Violet A. Reynolds petitioned the Court to redetermine respondent's determination of a $5,805 deficiency in her 1994 Federal income tax and an $1,161 accuracy-related penalty under section 6662(a). The principal issue we decide is whether payments received by petitioner under a settlement agreement are includable...
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