MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
Respondent determined a deficiency of $3,764 in petitioner's 1995 Federal income tax. The issue for decision is whether a lump-sum payment received by petitioner from his former employer is excludable from income under section 104(a)(2). Section references are to the Internal Revenue Code in effect for the year 1995.
FINDINGS OF FACT
Some of the facts have been stipulated...
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