Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1963 in the amount of $852.95.
The issues for decision are:
(1) Whether an amount of $5,749.73 received by petitioners in 1963 constituted back pay for the year 1961 subject to the provisions of section 1303, I. R. C. 1954.
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