OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for calendar years 1971 and 1972 of $1,133.25 and $3,503.18, respectively. The sole issue for decision is whether an amount received by petitioners from an annuity under the New York State Employees' Retirement System equal to the interest earned on petitioners' accumulated contributions to that system may be excluded from petitioners' gross income.
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