Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's refusal to afford him the benefits under Internal Revenue Code, section 107. A redetermination of a resulting deficiency in income tax for 1941 in the amount of $1,274.74 is sought.
At the hearing the parties orally stipulated certain facts and later filed a "supplementary stipulation of facts."
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