MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for 1991 in the amount of $11,930 and an addition to tax under section 6651(a)(1)
The following issues remain for decision:
(1) Is the payment that American Telephone and Telegraph Company (AT&T) made to petitioner in 1991 excludable from her gross income for...
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