MEMORANDUM OPINION
LARO, Judge:
This case is before the Court fully stipulated. See Rule 122. Norris O. and Betty J. Whitley petitioned the Court to redetermine deficiencies of $75,694 and $263 in their 1992 and 1993 Federal income tax, respectively. Following petitioners' concessions, we must decide whether their 1992 gross income includes $250,000 in punitive damages that they received during 1992. We hold it does. Unless otherwise indicated, section references...
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