- 9 -
the nature of severance pay, as respondent contends. See Sodoma
v. Commissioner, T.C. Memo. 1996-275, affd. 139 F.3d 899 (5th
Cir. 1998).
It follows that petitioner must include the lump-sum payment
in his 1995 income and respondent’s determination in this regard
is sustained.
Based on the foregoing,
Decision will be
entered for respondent.
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