Walter R. and Marilyn K. Easter - Page 1

                                 T.C. Memo. 1998-8                                    

                               UNITED STATES TAX COURT                                

                   WALTER R. and MARILYN K. EASTER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9166-96.                   Filed January 7, 1998.           

               Walter R. and Marilyn K. Easter, pro se.                               
               Allan D. Hill, for respondent.                                         

                                 MEMORANDUM OPINION                                   
               RAUM, Judge:  The Commissioner determined a $33,193                    
          deficiency in petitioners' 1992 Federal income taxes.  There are            
          two issues for consideration:  (1) Whether a settlement payment             
          of $135,000 and an incentive payment of $16,200 paid by State               
          Farm Insurance Company to petitioner Marilyn K. Easter to                   
          encourage her to settle her sex discrimination claim in a class             

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