OPINION.
RAUM, Judge:
The respondent determined deficiencies in income tax against petitioners for the years 1947 and 1948 in the amounts of $298.61 and $83.68, respectively. Petitioners claim overpayments of income tax for those years in the amounts of $46.50 and $25.32, respectively.
The issues are:
(1) Whether payments received by Clarence B. Jones from The Aetna Life Insurance Company during the years 1947 and 1948 were governed...
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