Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $2,914.06 in petitioners' 1976 Federal income taxes. Due to a concession by petitioner, the issues remaining for our determination are:
(1) Whether payments received by petitioner James J. Duffey, Jr., for research performed for the Minnesota Research and Development Center constituted a fellowship or scholarship properly excludable from gross income under...
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