Robert L. Allum - Page 31

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          hold that the entire settlement amount, including the portion               
          petitioner paid to his attorney pursuant to a contingent fee                
          agreement, must be included in petitioner’s gross income.  See              
          Helvering v. Horst, 311 U.S. 112 (1940); Lucas v. Earl, 281 U.S.            
          111 (1930).  We have carefully considered all remaining arguments           
          made by the parties for results contrary to those expressed                 
          herein and, to the extent not discussed above, conclude that                
          those arguments are without merit.                                          
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          


























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Last modified: May 25, 2011