MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $5,457 in petitioners' Federal income tax for 1994.
The sole issue for decision is whether $24,060.44 received by James J. Harford (petitioner husband) as a result of the termination of his employment is excludable from petitioners' 1994 gross...
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