Orin F. Farnsworth and Mary L. Farnsworth - Page 1

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                                 T.C. Memo. 2002-29                                   


                               UNITED STATES TAX COURT                                


              ORIN F. FARNSWORTH AND MARY L. FARNSWORTH, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14460-99.            Filed January 28, 2002.                

               Orin F. Farnsworth and Mary L. Farnsworth, pro sese.                   
               Paul K. Webb, for respondent.                                          


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               BEGHE, Judge:  Respondent determined a deficiency of                   
          $111,808 in petitioners’ joint Federal income tax for 1995.                 
               After concessions by the parties, there are two issues for             
          decision:  (1) Whether petitioners are entitled to exclude from             
          income, as a recovery of basis, any portion of the “contract                
          value” termination payments received in 1995 by petitioner Orin