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received by petitioner from the City are includable in
petitioner's gross income for 1994 under section 105(a).
We have carefully considered all remaining arguments made by
the parties for a result contrary to that expressed herein, and,
to the extent not discussed above, find them to be irrelevant or
without merit.
To reflect the foregoing and the concessions of
both parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011