Memorandum Opinion
RAUM, Judge:
Respondent determined a deficiency in petitioners' 1974 Federal income taxes in the amount of $2,339.47. After a concession by petitioners as to one adjustment made by the Commissioner, the only issue remaining for decision is whether petitioners may treat an amount of $6,580 as foreign income exempt from tax under section 911, I.R.C. 1954.
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