John R. and Sara E. Wise - Page 13

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          was terminated.  Indeed, he simply failed to present any evidence           
          that the settlement he received included a settlement of a tortlike         
          cause of action on account of personal injuries or sickness.                
               We have considered all of petitioners' other arguments and, to         
          the extent not discussed above, find them to be without merit.              
                In sum, the entire $1,125,000 settlement payment petitioner           
          received is includable in petitioners' 1989 gross income.                   
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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