Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated August 28, 1991, respondent determined a deficiency of $25,251 in petitioner's Federal income tax for 1988, along with an addition to tax, in the amount of $6,313, under section 6661. The issues presented are: (1) Whether amounts received by petitioner from his former employer constitute excludable (tax-exempt) damages received on account of personal injuries, and (2) whether...
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