MEMORANDUM OPINION
FOLEY, Judge:
By notice dated December 6, 1995, respondent determined a deficiency in petitioners' 1992 Federal income tax of $40,513 and an accuracy-related penalty of $8,103. After concessions, the issues we must decide are as follows:
1. Whether petitioners, pursuant to section 104(a)(2), are entitled to exclude amounts received in settlement of a class action suit. We hold they are not.
2. Whether petitioners, pursuant...
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