JACOBS, Judge:
Respondent determined a $185,833 deficiency in petitioners' 1992 Federal income taxes.
The deficiency herein arises from the parties' dispute over the characterization of settlement proceeds from a lawsuit that was brought by a corporation whose assets, including the lawsuit, were purchased by petitioners' two S corporations. The sole issue we must decide is whether the settlement proceeds received by the S corporations (and passed through...
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