Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $894.54 in the 1973 income tax of Race L.C. Kao and Lidia W.L. Kao. As a result of concessions by the Kaos, the sole issue is whether payments received by Race L.C. Kao, while serving as a postdoctoral research associate, constitute a scholarship or fellowship grant within the meaning of section 117.
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