David R. Green and Carolyn B. Green - Page 2

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          determined the following deficiencies in income tax, addition to            
          tax, and accuracy-related penalties:                                        
                                        Addition to TaxAccuracy-Related Penalty       
          Docket No.    Year  Deficiency   Sec. 6651(a)    Sec. 6662                  
          8933-94    1991  $3,466 ---   ---                                           
          6564-96    1992   3,435 ---   ---                                           
                    1993   2,823 ---   ---                                            
          26100-96  1994      2,946     $737                $589                      
                    1995      4,860          ---            972                       

          After concessions by petitioners, including the section 6651                
          addition to tax, the issues for decision in these consolidated              
          cases are:  (1) Whether petitioners are entitled, on the basis of           
          section 104(a)(2), to exclude the entire $36,000 payment, or a              
          portion thereof, that petitioner David R. Green received pursuant           
          to a settlement agreement, and (2) whether petitioners are liable           
          for accuracy-related penalties under section 6662 for taxable               
          years 1994 and 1995.                                                        
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Salt Lake City, Utah, at the time the petition was filed in                 
          docket No. 8933-94; petitioner David R. Green resided in                    
          Chandler, Arizona, and petitioner Carolyn B. Green resided in               
          Salt Lake City, Utah, at the time the petition was filed in                 
          docket No. 6564-96; and petitioner David R. Green resided in                
          Washington, Utah, and petitioner Carolyn B. Green resided in Salt           






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