Memorandum Opinion
COHEN, Judge:
Certain of the facts have been stipulated, and the stipulation of facts and supplemental stipulation of facts are incorporated herein by reference.
Petitioner was a resident of Piscataway, New Jersey, when he filed his petition in this case. During 1977 petitioner was a student at Hebrew Union College, Jewish Institute of Religion in New York City. He and his then wife filed a joint Federal income tax return for the...
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