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2. Amount of Income
The amount of income received by William Houchin,7 on behalf
of his corporation, from ARCO and Exxon in satisfaction of his
counterclaim that his royalties were underpaid is determined by
the terms of the settlement agreement. The settlement agreement
details an $8 million amount transferred to William Houchin and a
codefendant in satisfaction of their counterclaims that their
royalties were underpaid. The calculation detailed on the
“Houchin Disbursement Statement” dated December 31, 1998, shows
that William Houchin’s portion of the total settlement was
$6,145,315. In the notice of deficiency issued to W.C. Houchin
Corp. for the year ending December 31, 1998, respondent
determined a $6,145,315 adjustment to income for “ARCO
settlement-royalty income”. The parties stipulated that the
correct amount of income received by William Houchin from the
settlement agreement with ARCO and Exxon is $6,145,315. The
amount of income due William Houchin could be determined with
reasonable accuracy by the end of 1998.8
C. Conclusion
We hold that because the all-events test was satisfied in
1998 and the amount of income could be determined with reasonable
accuracy as of the end of 1998, the settlement agreement income
7 See supra note 4.
8 See supra note 4.
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