Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined a deficiency of $47.87 in petitioner's income tax for the year 1954. The sole issue for decision is what portion of the retirement allowance payments totalling $3,005.40, which petitioner received in said year from the New York State Employees' Retirement System, is includible in his gross income for Federal income tax purposes.
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