RAUM, Judge:
The Commissioner determined a $695 deficiency in petitioners' 1976 income taxes. The husband-petitioner (Col. Lyle) is a retired army officer who in 1976 served for 5 months as a Junior ROTC instructor in Odessa, Tex. At issue is whether a portion of the payments he received for such service under 10 U.S.C. sec. 2031(d) (1976) are excludable from gross income as a quarters or subsistence allowance, and whether petitioners are entitled to a deduction...
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