Memorandum Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioners' federal income tax for the calendar year 1973 in the amount of $150.09. The sole issue for our determination is whether petitioner, David F. Garber, was "gainfully employed on a substantially full-time basis" within the meaning of section 214, I.R.C. 1954.
This case was submitted under Rule 122 hence all of the facts have been stipulated...
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