Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year 1977 of $6,062.39. The issue for decision is whether a $15,000 payment received by petitioner from The New York Times in 1977 was excludable from income as compensation for personal injuries within the meaning of section 104(a)(2).
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