Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $4,470 deficiency in petitioners' joint individual Federal income tax for calendar year ending December 31, 1982. The deficiency resulted from the inclusion in income of the $20,000 lump sum payment petitioners received under title VII of the Regional Rail Reorganization Act of 1973 (herein "3R Act"),
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