Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding involves a deficiency of $414.06 in income tax determined against petitioner for 1949, and presents the question whether $3,440.02 received in that year by petitioner is taxable income under section 22(a), Internal Revenue Code of 1939.
Findings of Fact
Petitioner, an individual 73 years of age, lives in Durham, North Carolina. He filed his income tax return for the calendar...
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