Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Year Deficiency 1977 ........... $2,379 1978 ........... $1,021
The issue to be decided is whether petitioners are entitled to exclude from their taxable income $10,000 in 1977 and $5,000 in 1978 under the provisions of a treaty between the United States...
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