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relating to the leased automobile that it issued to him.
Based upon our examination of the entire record before us,
we find that petitioners have failed to satisfy the requirements
necessary under section 104(a)(2) for exclusion of the settlement
amounts in dispute from their gross income.8 We further find on
that record that petitioners have failed to carry their burden of
showing error in respondent’s determination, as modified on brief
in petitioners’ favor, that they must include the settlement
amounts in dispute (i.e., $33,255) in their taxable income for
1994.
To reflect the foregoing and the concession of respondent on
brief,
Decision will be
entered under Rule 155.
8We have considered all of the specific contentions and
arguments of petitioners relating to the settlement amounts in
dispute that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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