Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $5,983 in petitioners' income tax for the taxable year 1974. The only issue presented in this case is whether the payment of $22,200 to Vernon L. Anderson by Southern Illinois University in 1974 is includable in gross income under section 61, I.R.C. 1954,
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