The Commissioner determined deficiencies in income and victory tax against the petitioners for the calendar year 1943, in the respective amounts of $279.72 and $279.71. The petitioners contest the deficiencies and allege that the respondent erred in failing to give them the benefit of section 107 (a) of the Internal Revenue Code in respect to a lump sum payment received by Jerome Nast as physician for one family covering a period of 36 months or more.
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