Memorandum Findings of Fact and Opinion
CALDWELL, Commissioner:
The respondent determined a deficiency in the income taxes of the petitioners for the calendar year 1967 in the amount of $186.41. The sole issue for decision is whether $1500 paid to the husband petitioner as a resident physician's stipend is excludable from income as a fellowship grant under section 117(a)(1) of the Internal Revenue Code of 1954.
Findings...
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