MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $70,120 deficiency in petitioners' 1993 Federal income tax. The sole issue for decision is whether the $207,000 Richard Sherman (petitioner) received upon termination of his employment with International Business Machines Corporation (IBM) is excludable from petitioners' 1993 gross income pursuant to section 104(a)(2) as damages received on account of personal injury or sickness...
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