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petitioners received are not included in income in the year
received, but in the year the right to retain them is fixed.
Since the determination of petitioners’ rights to the deposits
did not occur in 1989, 1990, or 1991, the years before this
Court, the amounts are not included in petitioners’ gross income
for those years.
Because of our holding above, there is no need to consider
petitioners’ alternative argument.
An appropriate order
will be issued.
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Last modified: May 25, 2011