Memorandum Findings of Fact and Opinion
TURNER, Judge:
Respondent determined a deficiency in income tax against petitioner for the year 1944 in the amount of $1,545.20. The question presented is whether $5,545.29 of the amount of $9,645.29, received by petitioner in 1944 as compensation for services rendered, constituted "back pay" within the meaning of section 107 (d) (2) of the Internal Revenue Code.
Findings of Fact
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