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does not prevail because the Court has found that the
distributions were made under Cal. Govt. Code sec. 21150. In
other words, the distributions were not awarded solely as a
result of injury or sickness arising out of employment. See Kane
v. United States, supra at 1450.
Accordingly, this Court sustains respondent’s determination
that petitioners are not entitled to exclude any taxable portion
of the distributions from their gross income under section
104(a)(1).
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007