TIETJENS, Judge:
The respondent determined a deficiency in income tax of $7,426.81 for the calendar year 1953. The sole issue presented is whether the petitioner qualifies under the provisions of section 107(b), I.R.C. 1939.
FINDINGS OF FACT.
The facts stipulated are incorporated herein by reference.
John K. Standley, herein referred to as petitioner, and Anne Standley are, and at all times herein pertinent were, husband and wife....
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