Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency of $393.40 in the petitioners' income tax for the taxable year 1954. The issue presented is whether the respondent erred in disallowing an amount of $1,260.48 claimed by the petitioner Ruth Nicoll as an exclusion from gross income under section 105(d) of the Internal Revenue Code of 1954, relating to wages or payments in lieu of wages paid while an employee is absent...
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