MEMORANDUM OPINION
COHEN, Judge:
Respondent determined a deficiency of $4,315 in petitioners' Federal income tax for 1992 and an accuracy-related penalty pursuant to section 6662(a) of $863. The parties have settled the issues reflected in the notice of deficiency. We address here an overpayment issue raised in an amended petition, to wit, whether petitioners are entitled to exclude from income a $99,434 lump-sum payment received by Ronald Neil Robinson...
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