Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a $5,742 deficiency in petitioners' 1976 Federal income tax. The sole issue for decision is whether a payment received by petitioner Donald W. Margolis from International Business Machines Corporation upon the termination of his employment therewith is excludable from gross income.
Findings of Fact
Some of the facts have been stipulated and are found accordingly...
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