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BRADLEY v. COMMISSIONER

Docket No. 19074-02.

90 T.C.M. 317 (2005)

T.C. Memo. 2005-223

Charles E. and Noel K. Bradley v. Commissioner

United States Tax Court.

September 26, 2005.

Attorney(s) appearing for the Case

Charles E. and Noel K. Bradley, pro sese;

Robert E. Marum, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the 1995 taxable year in the amount of $4,676,578 and a penalty pursuant to section 6662(a) in the amount of $914,025.1 After concessions,2 the sole issue for decision is whether the $12 million petitioners received pursuant to a settlement is excludable from income under...

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