Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1967 in the amount of $219.28.
The deficiency arises from the fact that respondent has included in petitioner's income the sum of $1,096 which petitioner asserts is exempt in its entirety from tax under section 117 of the Internal Revenue Code of 1954.
Findings of Fact
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