MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent determined a deficiency of $37,114 in petitioner's 1992 Federal income tax and an addition to tax pursuant to section 6651(a)(1)
The issues for decision are: (1) Whether petitioner is required to include $138,799.18 in compensation for services, backpay, and interest on backpay in her 1992 gross income; (2) whether petitioner is required to include...
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