Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $2,460.12 in petitioners' Federal income tax for 1971. Concessions having been made by petitioners, the following issues remain for resolution:
1. Whether certain payments received in 1971 by petitioner Gloria B. Zimmermann qualify as a fellowship or scholarship grant within the meaning of section 117,
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