The Commissioner determined deficiencies in income tax of $305.37 for 1945 and $316.92 for 1946. The only issue for decision is whether $1,182.59 for 1945 and $1,385.65 for 1946 is exempt from tax as a cost-of-living allowance under section 116 (j) of the Internal Revenue Code.
FINDINGS OF FACT.
The individual returns of the petitioner for the taxable years were filed with the collector of internal revenue for the district of Washington.
The petitioner...
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