Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The Commissioner determined a deficiency in petitioners' Federal income tax for the calendar year 1968 in the amount of $581.23. The issues presented for our determination are: (1) Whether a stipend received by petitioner during 1968, while a resident at Jackson Memorial Hospital, Miami, Florida, constitutes a fellowship grant, partially excludable under section 117(a)(1)(B), Internal Revenue Code...
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