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LAGUAITE v. COMMISSIONER

Docket No. 23516-97.

79 T.C.M. 1750 (2000)

T.C. Memo. 2000-103

Francis G. Laguaite v. Commissioner.

United States Tax Court.

Filed March 27, 2000.

Attorney(s) appearing for the Case

Francis G. Laguaite, pro se. Gwendolyn C. Walker, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined a deficiency of $22,906 in petitioner's 1995 Federal income tax. After concessions1, the sole issue for our consideration is whether $76,740 that petitioner received upon termination from his former employer is excludable from petitioner's 1995 gross income pursuant to section 104(a)(2).2 We hold that it is not.

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