MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $191,580 deficiency in petitioners' 1992 Federal income tax. The sole issue for decision is whether the $600,000 Alain Massot (petitioner) received in 1992 as a result of the termination of his employment is excludable from petitioners' gross income pursuant to section 104(a)(2).
Unless otherwise indicated, all section references are to the Internal Revenue Code as in...
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