MEMORANDUM OPINION
WHALEN, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1994 of $77,415. Petitioners filed the instant petition seeking redetermination of that deficiency. They resided in Los Alamitos, California, at the time. We must decide the following three substantive issues: (1) Whether petitioners are entitled, pursuant to section 104(a)(2), to exclude from the gross income reported on their 1994 return the proceeds...
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