Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1983 and 1984 in the amounts of $93,422.40 and $12,730, respectively. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision whether amounts received by petitioners under an agreement with North American Coal Corporation (North American) are to be treated...
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