MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge.
Respondent determined deficiencies of $7,168 and $7,621 in petitioners' Federal income tax for taxable years 1998 and 1999, respectively.
The issue remaining for decision is whether certain wages that petitioner Milton L. Hildebran (Mr. Hildebran) received during each of the years at issue are excludable from petitioners' gross income for
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