MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined deficiencies in petitioner's 1992 and 1993 Federal income taxes of $8,402 and $322, respectively. The only issue for decision is whether disability payments to petitioner are excludable from gross income. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been...
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