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We sustain respondent's determination on this issue, as
adjusted by the concession mentioned above. In so doing, we have
considered each argument made by petitioners for a contrary
holding, and, to the extent not addressed above, find those
arguments to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
2(...continued)
because the settlement served to compensate Ms. Westmiller for
each of those years. We decline to do so. Suffice it to say
that petitioners are cash method taxpayers, and that the cash
method requires that they recognize all the income in 1992.
See sec. 1.451-1(a), Income Tax Regs.
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