FINDINGS OF FACT AND OPINION.
RAUM, Judge:
The respondent determined a deficiency in the income tax of the petitioner for the year 1946 in the amount of $228. The sole question is whether $1,355.76 received by the petitioner in 1946 from the Police Department of the city of Baltimore, Maryland, is exempt from tax under the provisions of section 22 (b) (5) of the Internal Revenue Code.
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