Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The respondent determined a deficiency in petitioners' income tax for the taxable year 1964 in the amount of $373.85. The parties have made concessions which can be given effect in a Rule 50 computation.
The sole issue remaining for our decision is whether the sum of $1,000 received by petitioner is excludable from gross income under section 117(a)(1), Internal Revenue Code of 1954,
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