MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1998 in the amount of $5,394.
The issue for decision is whether a portion of the compensation received by petitioner in his capacity as a Junior Reserve Officers' Training Corps (JROTC) instructor from a local school district is excludable from gross income.
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