Memorandum Findings of Fact and Opinion
CHABOT, Judge:
Respondent determined deficiencies in Federal income tax against petitioners for 1972 and 1973 in the amounts of $906 and $783, respectively.
After concession of one issue by petitioners, the issues remaining for decision are as follows:
(1) Whether the cash meals allowance received by petitioner Harold J. Koven from his wholly-owned employer is excludable
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