Memorandum Findings of Facts and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1960 and 1961 in the amounts of $305.61 and $399.38, respectively.
The sole issue is whether respondent correctly determined that certain payments made to Frederick W. Rembold, a retired policeman, in 1960 and 1961, after he had been retired on account of physical disability, were includable in his gross income....
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