MEMORANDUM OPINION
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's Federal income tax for 1993 in the amount of $5,398.
The issues for decision are: (1) Whether petitioner is entitled to exclude from gross income certain per diem payments which he received
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