Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the taxable years 1969 and 1970 in the amounts of $727.19 and $662.10, respectively.
The sole issue presented for decision is whether the petitioners are entitled to exclude $3,600 from their gross income in each of the years 1969 and 1970 as a scholarship or fellowship grant under section 117.
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