Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $495.49 in petitioners' Federal income tax for the year 1972. The issue presented is whether a portion of the stipend received by petitioner, Bruce A. Woodling, as a medical intern is excludable from gross income as a scholarship or fellowship grant under section 117(a)(1).
Findings of Fact
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