Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined a deficiency in income tax for the petitioners for the taxable year 1975 in the amount of $2,898.52. Due to concessions by the petitioners, the sole question before the Court is whether the amount paid to petitioner, Ronald Kletter, by Contra Costa County as program director of the Methadone Treatment Program is excludible from gross income under section 117.
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