The respondent has determined a deficiency in income tax for 1948 in the amount of $441.76. The petitioner Ephraim Banks received $2,562.50 from Polytechnic Institute of Brooklyn in 1948. He contends that the foregoing amount of payments is exempt from tax and alleges that the respondent erroneously included it in taxable income. In the event that the chief question is decided for the respondent, there is an alternative contention that $509 represents deductible expense....
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