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have failed to establish which portion, if any, was paid to
settle tort type claims for personal injuries. Petitioners bear
the burden of proving that a specific portion of the settlement
proceeds was paid to settle tort or tort type claims for personal
injuries and thus excludable under section 104(a)(2). See Rule
142(a). We hold that the entire $350,000 must be included in
petitioners’ 1994 gross income.
Decision will be entered
for respondent.
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Last modified: May 25, 2011