Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $29,223 in petitioner's Federal income taxes for 1984. After concessions by petitioner, the sole issue for decision is whether a payment of $94,367 received by petitioner from his former employer is excludable from taxable income under section 104(a)(2). Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for...
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