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REISMAN v. COMMISSIONER

Docket No. 18805-97.

79 T.C.M. 2075 (2000)

T.C. Memo. 2000-173

Arnold Reisman and Ellen Reisman v. Commissioner.

United States Tax Court.

Filed May 25, 2000.

Attorney(s) appearing for the Case

Arnold Reisman and Ellen Reisman, pro sese. Marc A. Shapiro, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $117,567 in petitioners' joint 1994 Federal income tax.

The only issue for decision1 is whether a $350,000 payment received by petitioners from Case Western Reserve University in 1994 is excludable from gross income under section 104(a)(2).2

FINDINGS OF FACT

Some of the facts have been...

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