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After concessions, the sole issue remaining for decision is
whether petitioner is entitled to exclude, pursuant to section
104(a)(2), $283,394.56 of settlement proceeds received from State
Farm Insurance (State Farm) in 1992.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Independence, Kentucky, at the time she
filed her petition.
From September or October 1975 through May 1976, petitioner
worked for the Chuck Clayton Insurance Agency (Chuck Clayton), an
agent of State Farm, in Whittier, California. Petitioner was not
an insurance agent or trainee agent for Chuck Clayton or State
Farm. Petitioner resigned from her job with Chuck Clayton in May
1976. She has not been employed by either Chuck Clayton or State
Farm at any time thereafter.
In May 1976, petitioner moved to Cincinnati, Ohio, and began
work as a receptionist for Robert G. McGraw & Co., an independent
insurance agent, in June 1976. Petitioner subsequently became a
licensed insurance agent.
2At trial, petitioner conceded that $16,200 of her
settlement award, which constituted an "incentive cash" payment
from State Farm, was includable in her gross income for 1992.
See Berst v. Commissioner, T.C. Memo. 1997-137.
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