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the amount of $914,025.1 After concessions,2 the sole issue for
decision is whether the $12 million petitioners received pursuant
to a settlement is excludable from income under section
104(a)(2).
FINDINGS OF FACT
I. Background
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time this petition
was filed, petitioners resided in Darien, Connecticut. Noel K.
Bradley is a party to this case only because she filed a joint
Federal income tax return with her spouse, Charles E. Bradley
(petitioner or Mr. Bradley), for their 1995 tax year.
Mr. Bradley received his bachelor’s degree in economics from
Yale University in 1951 and his M.B.A. degree in accounting from
New York University School of Business in 1957. After his
graduation from Yale, petitioner worked at Price Waterhouse until
1953 when he joined the U.S. Navy as a lieutenant junior grade.
He returned to Price Waterhouse in 1956 where he continued to
work until 1967, eventually becoming a general partner of the
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code for the year in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
2 By stipulation, respondent conceded the sec. 6662(a)
penalty, and petitioners conceded all other adjustments for 1995
as listed in the notice of deficiency.
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