Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent has determined deficiencies in petitioners' income tax for the years 1968 and 1969 in the amounts of $426.23 and $1,461.81, respectively. The issues remaining for our decision are (1) whether the petitioners are entitled to exclude certain stipends from their gross income for 1969 as a fellowship or scholarship grant under section 117
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