Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $2,414 deficiency in petitioners' joint individual Federal income tax for calendar year ending December 31, 1983. The deficiency results from the inclusion of an additional $748 petitioners received from Conrail United Transportation Union Productivity; $7,700 received under title VII of the Regional Rail Reorganization Act of 1973 (herein "3R Act"),
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