Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1971 in the amount of $900.25. The only issue for decision is whether an amount paid to Heena N. Thakkar as a stipend while she was serving an internship at Allegheny General Hospital constitutes a scholarship or fellowship grant within the meaning of section 117, I.R.C. 1954.
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