D. Sam Scheele - Page 13

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             his argument that the Weisel payment is excludable under section                                     
             104(a)(2).  Petitioner has failed to carry his burden of proof                                       
             and, thus, petitioner is liable for the penalty imposed by                                           
             section 6662(a).                                                                                     

                                                                   Decision will be entered                       
                                                            for respondent.                                       



































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