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entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a $25,056 deficiency in petitioners’
1999 Federal income tax. All adjustments that give rise to the
deficiency have been agreed upon by the parties-–their dispute
involves an item reported on petitioners’ 1999 Federal income tax
return. John Bothe (petitioner) sued his former employer.
Petitioners included the settlement proceeds from that lawsuit in
the income reported on their 1999 return. They now take the
position that it was a mistake to have done so. The issue for
decision is whether those settlement proceeds are excludable from
income pursuant to section 104(a)(2).
Background
Some of the facts have been stipulated and are so found.
Petitioners are married to each other. They filed a timely joint
1999 Federal income tax return. At the time the petition was
filed in this case, they resided in Corfu, New York.
Years ago, at age 19, petitioner began working at the New
Jersey Sports and Exposition Authority, a.k.a. the Meadowlands
racetrack (the Meadowlands). In 1979, he became an assistant
race track announcer there. In 1990, petitioner became the
head race track announcer. Starting as teenager and continuing
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