Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of petitioner for the taxable year 1954 in the amount of $236.74.
The sole issue is whether petitioner, a retired Navy officer, may exclude from gross income 20 per cent of his retirement pay based on length of service under section 104(a)(4) of the 1954 Code.
Findings of Fact
Most of the facts have been stipulated and are found accordingly.
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