Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency in petitioner's income tax for 1965 in the amount of $244. The sole issue presented for our decision is whether certain payments, in the total amount of $2,325.54, received by petitioner during 1965 while a medical trainee at St. Luke's Hospital Center, New York, New York, represented a scholarship
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