Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $330.14 in petitioners' income tax for the taxable year 1969. Two questions are presented for our consideration: (1) Did the stipend received by petitioner William S. Kammerer during the year 1969 constitute a fellowship within the meaning of section 117, I.R.C. 1954,
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