Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $791.00 in petitioners' Federal income tax for the taxable year ended December 31, 1978. In their petition, as amended, petitioners disputed respondent's determination and also claimed an overpayment for said taxable year. The sole issue for decision is whether amounts received by each of petitioners as a teaching assistant are excludable from gross income as...
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