Memorandum Findings of Facts and Opinion
JOHNSTON, Commissioner:
Respondent determined a deficiency in the Federal income tax of the petitioner for the year 1968 in the amount of $339.02. The issue for decision is whether amounts received by petitioner, Michael D. Birnbaum, in the taxable year 1968 constituted a fellowship grant, excludable from gross income under section 117(a)(1)(B) of the Internal Revenue Code.
Findings...
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