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the attorney as a contingency fee).
On the record before us, we find that petitioner is required
to include in her gross income the entire amount of the $170,000
settlement.
Petitioner further argues that if the Court were to conclude
that the $170,000 settlement is includible in her gross income,
such settlement
would be income that should be claimed in each of the
eight tax years used in the computation and justifica-
tion of these funds, the period during which they were
earned. * * * [Reproduced literally.]
As we understand petitioner’s argument, the $170,000 settlement
should be taken into account over an eight-year period, the
approximate period of years to which such settlement for back
wages pertained.
Section 451(a) provides in pertinent part:
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION.
(a) General Rule.--The amount of any item of gross
income shall be included in the gross income for the
taxable year in which received by the taxpayer, unless,
under the method of accounting used in computing tax-
able income, such amount is to be properly accounted
for as of a different period.
Section 451(b) through (g) and the regulations thereunder pre-
scribe special rules setting forth exceptions to the general rule
in section 451(a). None of those special rules applies in the
instant case. For the year at issue, petitioner was, and was
required to be, on the cash method of accounting.
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