Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $704 in petitioners' Federal income tax for the year 1973. The issue for decision is whether amounts paid in 1973 to petitioner Richard Bogdan as a resident in podiatry by the California College of Podiatric Medicine is excludable from his gross income under the provisions of section 117, Internal Revenue Code.
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