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Respondent determined a deficiency in petitioners’ income
tax of $810 in 1998. The issue for decision is whether a
settlement payment that Arthur F. Reid (petitioner) received in
1998 is excludable from petitioners’ gross income under section
104(a)(1) or (2).
Respondent also determined that petitioners (1) received
$322 in income related to the sale of securities, (2) received
$16 in interest income from the State of Virginia, and (3) are
not entitled to a deduction of $107 claimed on Schedule A,
Itemized Deductions. Petitioners did not present any evidence
concerning these determinations; therefore, we deem them
conceded. Petitioners resided in Fairfax, Virginia, at the time
they filed the petition.
Background
In 1995 petitioner worked as a cashier for Chevron Corp.
(Chevron) in Florida. Petitioner asserts that he lifted a
5-pound bucket of ice at work and injured his shoulder.
Petitioner claimed that he was no longer able to work. He filed
a claim for workmen’s compensation benefits, but his claim was
denied. Petitioner’s employment with Chevron ended. The record
is not clear as to the reason for the termination of petitioner’s
employment.
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