Memorandum Findings of Fact and Opinion
SACKS, Commissioner:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1968 in the amount of $237.51. The sole issue for decision is whether the sum of $1,158.84 received in 1968 by petitioner William J. Orlicky as "sick pay" under a health and insurance plan for sickness was properly excludable from income under the provisions of section 105(d) of the Internal Revenue Code...
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