Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $10,920 in petitioners' Federal income tax for 1984. The sole issue for decision is whether a cash award received by David P. Crowell in 1984 is excludable from gross income under section 74(b). All section references are to the Internal Revenue Code, as amended and in effect for the year in issue.
Findings of Fact
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