Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies of $449.78 and $362.00 in petitioners' Federal income tax for the years 1975 and 1976, respectively. The only issue for determination in this case is whether petitioners are entitled to an exclusion, beyond that allowed by respondent, of part of amounts received by petitioner-husband as a retirement pension.
Findings of Fact
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