Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined a deficiency of $409.71 in income tax for the calendar year 1945. The sole issue is whether the sum of $1,250, received by petitioner Frederick V. Waugh (hereinafter referred to as petitioner), as an award in an essay contest conducted by the American Farm Economic Association, constitutes gross income under section 22(a), Internal Revenue Code, or is excludable from gross income...