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GROSS v. COMMISSIONER

Docket No. 3440-98.

80 T.C.M. 648 (2000)

T.C. Memo. 2000-342

Ronald N. and Karen M. Gross v. Commissioner.

United States Tax Court.

Filed November 7, 2000.

Attorney(s) appearing for the Case

Mark A. Pridgeon, for the petitioners. Blaine C. Holiday, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for taxable years 1993 and 1994 of $120,226 and $39,914, respectively. The sole issue for decision1 is whether petitioners may exclude from gross income under section 104(a)(2)2 three sets of payments received during the years...

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