Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies of $3,838.92 and $4,369.91 in petitioner's Federal income taxes for 1976 and 1977, respectively. The only issue for decision is whether petitioner may exclude from his gross income any amount as a "rental allowance" under section 107(2).
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
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