Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined deficiencies in petitioners' income tax as follows:
Year Deficiency 1965 ............. $112.13 1966 ............. 647.29
The issue for decision is whether the payments petitioners received as per diem living expense allowances during the taxable years 1965 and 1966 are includable in their gross income under section 61(a) of the 1954...
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