Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a $431.69 deficiency in petitioners' 1969 Federal income tax. The sole issue is whether T. Craig Ferrill (hereinafter petitioner) is entitled to exclude $300 per month of payments received as a medical resident from St. Paul Hospital as a fellowship grant under section 117(a)(1)(B) and (b)(2).
Findings of Fact
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