RUWE, Judge: Respondent determined deficiencies in petitioners’ 1981 and 1982 Federal income taxes in the amounts of $174,428.31 and $109,796.67, respectively. The issues for decision are: (1) Whether petitioner, Thomas O’Malley, received unreported income in the amounts of $266,280.55 and $212,212.34 for the taxable years 1981 and 1982, respectively, from the payment by Central States Pension Fund of his…
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