William Joseph and Robin B. Westmiller - Page 5

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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.                          

          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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