Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $645.92 in petitioners' Federal income tax for the year 1967. The only issue before us is whether a stipend in the amount of $9,076, received by petitioner Edward A. Ballerini (hereinafter referred to as petitioner) during 1967 while a resident at Gorgas Hospital, Panama Canal Zone, constitutes a scholarship or a fellowship grant, $3,600 of which is excludable under...
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