Memorandum Findings of Fact and Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181 and 182.
Respondent determined a deficiency in petitioners' 1989 Federal income tax in the amount of $2,362. The sole issue for decision is whether $18,143, which petitioners received in 1989 as "Extended Termination Payments" from the State Farm Insurance Companies...
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