Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency in petitioners' Federal income tax return for the taxable year 1981 in the amount of $6,187, and an addition to tax under section 6653(a)
The issues for determination are:
(1) Whether an exclusion from gross income claimed by petitioners in 1981 in connection with a plan for assignment of income is...
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