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MADSON v. COMMISSIONER

Docket No. 26275-83.

55 T.C.M. 1351 (1988)

T.C. Memo. 1988-325

Elmer A. Madson and Hazil Madson v. Commissioner.

United States Tax Court.

Filed July 27, 1988.

Attorney(s) appearing for the Case

Steven J. Madson, 1400 Leader Bldg., Cleveland, Ohio, for the petitioners. Joseph R. Peters, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency in petitioners' 1980 Federal income tax in the amount of $5,863. The sole issue we must decide is whether any portion of a $41,000 settlement payment received by petitioner, Elmer Madson, represents an amount excludable from his gross income under section 104(a)(2).1

Findings of...

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