Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
1976 ............ $3,339 1977 ............ 2,504
Due to concessions, the sole issue remaining for our determination is whether the value of lodging facilities furnished to petitioner Albert M. Van Huff is properly excludable from petitioners' gross income
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