Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies of $5,331.97 and $440.62 in petitioners' income taxes for the taxable years 1947 and 1948, respectively. The questions to be decided are (1) whether the sum received by petitioner Joseph P. Deery in settlement of a law suit in 1947 constituted back pay within the provisions of section 107(d), Internal Revenue Code of 1939; and (2) whether traveling expenses incurred...
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