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105(a), the agreement effectively prevents any accretion to
petitioner’s wealth attributable to the payments. See
Commissioner v. Glenshaw Glass Co., supra. Consequently, the
payments received by petitioner during 1998 are not income to
petitioner and therefore are not includable in petitioners’
income for that year.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011