Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1974 in the amount of $2,404.42. The only issue for decision is whether a payment of $11,600 made to petitioner Fred A. Whitehead by Southern Illinois University in 1974 is includable in gross income under section 61, I.R.C. 1954,
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