KOSIKOWSKI v. COMMISSIONER

Docket No. 2566-69 SC.

29 T.C.M. 1340 (1970)

T.C. Memo. 1970-289

Richard E. Kosikowski and Mary J. Kosikowski v. Commissioner.

United States Tax Court.

Filed October 8, 1970.


Attorney(s) appearing for the Case

Richard L. Powell, for the petitioners. David S. Meisel, for the respondent.


Memorandum Findings of Fact and Opinion

WITHEY, Judge:

Respondent determined deficiencies in petitioners' income tax as follows:

  Year              Deficiency

  1965 ............. $112.13
  1966 .............  647.29

The issue for decision is whether the payments petitioners received as per diem living expense allowances during the taxable years 1965 and 1966 are includable in their gross income under section 61(a) of the 1954...

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